Shareholders Communication Policy


(Incorporated in the Cayman Islands with limited liability)
(the “Company”)
(Stock Code: 1161)



1.1This Shareholders Communication Policy (the “Policy”) aims to set out the provisions with the objective of ensuring that Company’s shareholders, both individual and institutional (collectively, “Shareholders”), and, in appropriate circumstances, the investment community at large, are provided with ready, equal and timely access to balanced and understandable information about the Company (including its financial performance, strategic goals and plans, material developments, governance and risk profile), in order to enable Shareholders to exercise their rights in an informed manner, and to allow Shareholders and the investment community to engage actively with the Company.

1.2For the purpose of this Policy, references to the investment community is intended to include the Company’s potential investors as well as analysts reporting and analysing the Company’s performance.

2.General Policy

2.1The Board of Directors of the Company (the “Board”) shall maintain an on-going dialogue with Shareholders and the investment community, and will regularly review this Policy to ensure its effectiveness.

2.2Information of the Company shall be communicated to Shareholders and the investment community mainly through the Company’s financial reports (interim and annual reports), announcements, circulars and other corporate publications made available on the website of the Company at and the HKExnews website at, and the direct communication platform in the annual general meeting held every year and any other general meetings that may be convened as required.

2.3Effective and timely dissemination of information to Shareholders and the investment community shall be ensured at all times.

2.4Any questions regarding this Policy shall be directed to the Company Secretary.

3.Communication Strategies

Shareholders’ enquiries

3.1Shareholders should direct their questions about their shareholdings to the Company’s Share Registrar.

3.2Shareholders and the investment community may at any time make a request for the Company’s information to the extent such information is publicly available.

3.3Shareholders and the investment community may send their enquiries in respect of the Company by addressing them to the Company Secretary.

Corporate Communication

3.4Corporate communication (as defined in the Rules Governing the Listing of Securities of The Stock Exchange of Hong Kong Limited (the “Listing Rules”), any documents issued or to be issued by the Company for the information or action of Shareholders, including, but not limited to, the Directors’ report and annual accounts together with a copy of the independent auditor’s report, the interim report, a notice of meeting, a circular and a proxy form) will be provided to Shareholders in plain language and in both English and Chinese versions to facilitate Shareholders’ understanding. Shareholders have the right to choose the language (either English or Chinese) or means of receipt of the corporate communications (in hard copy or through electronic means).

3.5Shareholders are encouraged to provide, amongst other things, in particular, their email addresses to the Company in order to facilitate timely and effective communications.

Corporate Website

3.6The Company’s website provides comprehensive and updated information about the Company, including our news, financial results, financial statements, announcements, circulars, Memorandum and Articles of Association, composition of the Board, Audit Committee, Nomination Committee, Remuneration Committee and Investment Advisory Committee and the terms of reference of the Company’s Audit Committee, Nomination Committee, Remuneration Committee and Investment Advisory Committee. Information on the Company’s website is updated from time to time.

3.7Information submitted by the Company to The Stock Exchange of Hong Kong Limited for publication on the HKExnews website will also be posted on the Company’s website immediately thereafter in accordance with the requirements of the Listing Rules. Such information includes financial statements, results announcements, announcements, circulars, notices of general meetings, proxy forms, monthly return and next day disclosure return etc.

3.8All press release relating to the Company’s results announcements (if any) will be made available on the Company’s website.

3.9All the Company’s news regarding the major events and activities of the Group will be made available on the Company’s website.

Shareholders’ Meetings

3.10Shareholders are encouraged to participate in general meetings or to appoint proxies to attend and vote at meetings for and on their behalf if they are unable to attend the meetings.

3.11Appropriate arrangements for the annual general meetings and other general meetings shall be in place to encourage Shareholders’ participation.

3.12The process of the Company’s general meeting will be monitored and reviewed on a regular basis, and, if necessary, changes will be made to ensure that Shareholders’ needs are best served.

3.13Board members, in particular, the chairmen of Board committees or their delegates, appropriate management executives and representative(s) of external auditors will attend annual general meetings to answer Shareholders’ questions.

Investment Market Communications

3.14Investor/analysts briefings and one-on-one meetings, media interviews and marketing activities for investors etc will be available where necessary in order to facilitate communication between the Company, Shareholders and the investment community.

3.15The Company’s Directors and employees who have contacts or dialogues with investors, analysts, media or other interested outside parties are required to comply with the relevant disclosure obligations and requirements under the Listing Rules.

4.Shareholder Privacy

4.1The Company recognises the importance of Shareholders’ privacy and will not disclose Shareholders’ information without their consent, unless required by law to do so.

March, 2012