Anyone within the organization who has a privileged relationship to the Company should not trade the Company's securities based on undisclosed material information or facts.

The policy is intended to avoid the conflict of interest as well as to govern the company securities trading, specifically that everyone should not trade the company's securities while having information or material facts that will not be/has not been published, dissemination of information or material facts selectively as well as the tipping related to the information or material facts that will not be/has not been published.

Anyone within the Company refers to:

1. Commissioners, Directors, or employees;
2. Major shareholders;
3. Individuals with positions or professions or relationship to the Company have access to inside information; or
4. Anyone within the last 6 (six) months who is no longer a part of number a, b and c above.