- 1. General Policy
- 2. Shareholders’ Rights
- 3. Communications Principles
- 4. Engagement with Investment Community
- 5. Company Contacts
- 6. Shareholder Privacy
1. General Policy
1.1 The Company treats all shareholders of the Company (" Shareholders ") fairly and equitably so that Shareholders can make informed decisions when exercising their rights as shareholders and have the opportunity to communicate their views on matters affecting the Company.
1.2 The Company also endeavours to give Shareholders a balanced and understandable assessment of its performance, position and prospects.
1.3 The Company is committed to making timely, full and accurate disclosures and distributing corporate communications materials¹ in accordance with the listing rules of the SGX-ST and the Code.
1.4 All disclosures are submitted to SGX-ST through SGXNet and are made available on the Company’s corporate website. Should material disclosures be inadvertently made to a select group, the Company will ensure the same disclosures are made public as soon as practicable via SGXNet.
1.5 This IR Policy is subject to regular review by the Company’s senior management to ensure its effectiveness. Updates, where appropriate, will be made to reflect current best practices in our communications with Shareholders and the investment community.
(1) Refers to any document issued or to be issued by the Company for the information or action of Shareholders, including, but not limited to, the annual reports, presentation materials, factsheets, notices of meeting, circulars and proxy forms.
2. Shareholders’ Rights
2.1 In treating all Shareholders fairly and equitably, the Company is committed to put in place the following arrangements:
(a) Facilitating the opportunity for Shareholders to participate effectively in and vote at general meetings of Shareholders;
(b) Informing Shareholders of the resolutions that they are voting on and the voting procedures involved;
(c) Allowing corporations which provide nominee or custodial services to appoint more than two proxies so that Shareholders who hold shares through such corporations can attend and participate in general meetings of Shareholders as proxies; and
(d) Publishing minutes of general meetings of Shareholders on its corporate website as soon as practicable and ensuring that the minutes record substantial and relevant comments or queries from Shareholders relating to the agenda of the general meeting, and responses from the Board and Management.
3. Communications Principles
3.1 The Company strives to provide relevant and accurate information to Shareholders and the investment community in a timely and effective manner.
3.2 The Company will use clear and plain language in its communication with its Shareholders where possible.
3.3 The Company endeavours to provide a consistent level of disclosure on both positive and negative developments of the Company.
3.4 The Company communicates only through designated spokespersons and via its announcements made through SGXNET to SGX-ST and posted on the Company’s corporate website.
3.5 The Company's designated senior spokespersons will establish and maintain regular dialogue with Shareholders, to solicit and understand the views of Shareholders through meetings with Shareholders, analysts briefings, media interviews, and investor roadshows.
3.6 The Company does not comment on share price movement or fluctuations in share trading volumes, nor does it disclose trade-sensitive information that may compromise its competitive position in the market.
3.7 The Company will give reasonable access to analysts, brokerage firms, investment banks and the media to help them formulate informed opinions of the Company, but not seek to influence those opinions.
3.8 The Company does not respond to market rumours or speculation. However, clarifications will be promptly made through announcements via SGXNet in the event that information or rumours indicate material information has been leaked or are in fact false or inaccurate.
3.9 The Company observes a “blackout period” commencing one month before the announcement of the Company's half year and full year financial statements. During this period, the Company does not comment on industry outlook, the Group’s business performance and financial results.
3.10 The Company will identify any forward-looking statements made in its written documents and accompany these statements with meaningful cautionary language which warns readers that risks, uncertainties and other factors could cause actual results to differ materially from the expectations expressed in the forward-looking statement.
4. Engagement with Investment Community
4.1 The Company is committed to actively engage and establish regular two-way communication with Shareholders and the wider investment community
4.2 The Company actively engages Shareholders and the investment community via but not limited to, the following:
(a) Annual General Meeting (“ AGM ”) and Extraordinary General Meeting (“ EGM ”), if necessary;
(b) financial results announced via SGXNet and posted on the Company’s corporate website;
(c) one-on-one / group meetings;
(d) site and plant visits;
(e) annual reports;
(f) news releases and statements;
(g) media interviews;
(h) notices of and explanatory memorandums for AGMs and EGMs; and
(i) corporate website ( www.nti-nanofilm.com ).
4.3 The Company’s general meetings are the principal communication channels with Shareholders and for Shareholders’ participation.
4.4 A notice of general meeting, listing all items of business to be transacted at the general meeting, will be announced on the SGXNet and posted on the Company’s corporate website, or a copy sent to Shareholders, within the stipulated notice period prior to the general meeting. As and when a general meeting is to be held, a circular, an addendum or other document containing details of the matters proposed for Shareholders’ consideration and approval will be announced on the SGXNet and posted on the Company’s corporate website, or a copy sent to Shareholders, for their information.
4.5 The Company will table separate resolutions at general meetings on each substantially separate issue unless the issues are interdependent and linked so as to form one significant proposal. Where the resolutions are ‘bundled’, the Company will explain the reasons and material implications in the notice of meeting.
4.6 Members of the Board, Company’s senior management, and the external auditors of the Company are in attendance at all general meetings. Shareholders are given the opportunity to pose their questions to the Company and communicate their views on various matters before the general meeting through various channels. The Board and the Company’s senior management will answer all substantial and relevant questions raised by Shareholders, which are announced on the SGXNet and posted on the Company’s corporate website, before the general meeting.
4.7 The Company supports and facilitates voting by poll at all general meetings. The poll results are announced via SGXNet on the same day of each general meeting.
4.8 The Company meets with current and prospective investors, media and analysts at appropriate times, and participates in investor roadshows and sector conferences throughout the year.
4.9 Upon the release of half and full-year financial results, as well as quarterly business updates, the announcement, as well as relevant materials, will be released via SGXNet and will be made available on the Company’s corporate website.
4.10 The Company discloses in its Annual Report and/or Sustainability Report its business strategy, business performance, outlook and future plans as well as its key areas of focus in relation to the management of stakeholder relationships during the reporting period.
4.11 The Company maintains a corporate website ( www.nti-nanofilm.com ). Both current information and archives of previously released information including financial results announcements, annual reports, SGXNet announcements, presentation materials, and other relevant corporate information are made available on the Company’s corporate website.
5. Company Contacts
5.1 Shareholders can contact the Company’s Share Registrar at the following address / numbers:
Boardroom Corporate & Advisory Services Pte. Ltd.
1 Harbourfront Avenue #14-07
Keppel Bay Tower
Telephone: +65 6536 5355
Facsimile: +65 6536 1360
5.2 Shareholders and the investment community may contact the Company’s IR team via e-mail at firstname.lastname@example.org to raise their queries.
6. Shareholder Privacy
6.1 The Company recognises the importance of Shareholders’ privacy and will not disclose Shareholders’ information, without their consent, unless required by or permitted under applicable laws.