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to be entered in the Central Registry Agency (“CRA”) system before

the capital markets instruments are traded on the exchange. Some

examples of grounds for inclusion of a person on the list are: the reg-

istration and the announcement of the representative of a legal person

in the Board of Directors member, appointment, change of position,

promotion, consultancy/audits, work in the parent company, etc.

Different from the former communiqué, if there is an amendment

to the Insiders List, the necessary updates have to be made within two

days thereafter.

According to the former communiqué, the Insiders List had to be

filed by the issuer for a period of eight years; whereas, the new

Communiqué employs the CRA for record-keeping and in the event of

a request, it shall be sent to the Capital Markets Board and the relevant

stock exchange.

Confirmation of News or Rumors

Issuers are obliged to disclose regarding the accuracy of the news

or rumors in the media should they relate to inside information.

However, the popularity and circulation rate of the media, as well as

the evaluation of the Board of Directors as to whether or not this infor-

mation is inside information, are essential to decide whether a disclo-

sure is needed.

Disclosure of Forward Looking Statements

Essential changes are made in the Communiqué to which the

investor relations departments should pay close attention.

If the issuer wants to disclose forward looking statements, a reso-

lution of the Board of Directors or a written approval of the competent

persons to whom the Board of Directors has granted authority shall be

obtained.

These disclosures can be made maximum four times a year. The

disclosure can be announced separately in public disclosure platform

(“PDP”) or, it can be incorporated in the annual reports. Nevertheless,

if any changes occur in respect of such disclosures, a new disclosure

shall be made immediately.

CAPITAL MARKETS LAW

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