Shareholder Communication Policy
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0) Corporate structure and scope
Tanqory PTE. LTD. (Singapore, UEN 202448997H) is the ultimate parent and holding company of the Tanqory group, including its wholly-owned subsidiaries Tanqory Inc. (Delaware, USA) and Tanqory OÜ (Estonia). Tanqory Inc. is the contracting entity and merchant of record for every product and service Tanqory sells to merchants and customers worldwide — Tanqory PTE. LTD. itself does not contract with, bill, or hold a direct customer relationship with any merchant or customer. This document is adopted by Tanqory PTE. LTD. as the group's holding company and applies group-wide, including to Tanqory Inc.'s and Tanqory OÜ's operations, unless a section below states a narrower scope.
1) Principles and scope
Provide transparent, timely, accurate, and fair information to shareholders to support investment decisions and good governance. Covers all channels: annual/quarterly reports, website/IR portal, email, AGM/EGM, and material disclosures. Follow applicable securities/capital market laws and fair disclosure practices. Use clear language and digital formats accessible to shareholders globally. Provide opportunities for Q&A/feedback via designated channels. Protect inside information and avoid selective disclosure. Define communication owners (IR/Legal/Company Secretary) and approval process before release. Review this policy at least annually or when laws/standards change. Publish on the company website and notify shareholders via durable medium for material changes. Do not use communications to influence price or mislead.
2) Channels and frequency
Annual report/financial filings published via website/email/stock exchange (if required). Quarterly results released per financial calendar with slides/management commentary where appropriate. AGM/EGM notices sent per law/bylaws with agendas and full materials. Material events (e.g., acquisitions, fundraising, senior leadership changes) disclosed immediately per applicable market rules. IR Portal/website serves as primary repository for news, announcements, reports, and FAQs. Inquiry channels: ir@tanqory.com for finance/business; legal@tanqory.com for legal/governance. Respond within reasonable time; if public information, post on website for fairness. Social media used only for public information; no inside or unpublished data. Provide summaries/Q&A from AGM/EGM on the website. During blackout around earnings, limit communications to avoid inside information.
3) Material disclosures and fair practice
Comply with market rules on material information; disclose publicly and simultaneously via required channels. Approval workflow: Finance/Legal/IR/CEO/Board verify accuracy/completeness before release. Avoid selective disclosure; if limited briefings occur, promptly disclose publicly via the same channels. Set blackout periods before/after earnings; restrict performance/outlook communications to publicly disclosed data. Keep evidence of disclosures (time/channel/content) for auditability. Issue clarifications if rumors/misinformation materially affect the company, consistent with market rules. Present disclosures clearly with necessary context; avoid exaggeration. Disclose key risks and factors affecting performance/strategy in the annual report or relevant filings. Maintain a communications calendar (financial releases, AGM/EGM) and publish in advance. Periodically review disclosure practices against global norms/investor expectations.
4) Shareholder rights and engagement
Respect legal/bylaw rights: voting, dividends per resolutions, and adequate information. Provide AGM/EGM notices/agendas/materials at least the legally required period and via website. Offer channels for pre-submitted questions/proposals; answer in meeting or publish after. Support proxies for shareholders who cannot attend. Clearly explain voting procedures; ensure auditable counting. If using e-voting, secure the system. Provide sufficient information on directors, executives, and key proposals. Hold meetings at accessible times/venues (or online) to encourage participation. Record and publish voting results and minutes as required. Provide post-meeting contact channels for further queries. Protect shareholder personal data in registry/communications per privacy law.
5) Inside information and blackout management
Set blackout periods before/after earnings or designated events; limit communications that could reveal inside information. Notify management/employees/directors and anyone involved in investor communications of blackout timelines. Prohibit insider trading; comply with Insider Trading Policy. Investor/media communications during blackout go through IR/Legal and are limited to publicly disclosed information. Log questions/answers during blackout to confirm only public information shared. If inside information leaks, assess and disclose formally without delay per market rules. Provide regular training/guidance on communication and trading restrictions for insiders. Maintain insider lists for material events. Any blackout exception requires written approval from authorized approver. Review blackout effectiveness annually and improve based on lessons learned.
6) Handling complaints and feedback
Provide channels for complaints/feedback via ir@tanqory.com or IR portal form; target initial response within 7 business days. Log complaints/feedback with owners and closure timelines. If complaints involve inside information/securities, escalate to Legal/Compliance for action. Material/reputational complaints reported to management/board per escalation and disclosure rules. Communicate outcomes to complainants within reasonable time. Track complaint/feedback statistics to identify trends and improve communications. Privacy-related complaints follow Privacy/DPA Policy and applicable law. Keep complainant data confidential per privacy policy/law. Provide escalation path if complainant is unsatisfied (e.g., senior management or audit committee). Retain records per Retention Policy for auditability.
7) Roles and responsibilities
Board oversees this policy and receives annual reports on shareholder communications and disclosure compliance. CEO/CFO lead financial/material disclosures with IR/Legal. IR/Company Secretary prepares shareholder meeting materials, announcements, and responds to queries per SLA. Legal/Compliance checks alignment with securities/market laws and manages blackout/insider trading policy. IT/Web maintains readiness and security of IR Portal/website. Business managers must submit accurate, timely information on material matters. Insiders must follow communication and trading restrictions. Review/update communication/approval procedures when new rules or lessons emerge. Provide training (IR, disclosure, insider trading, blackout) to those communicating with shareholders. Make contact details and feedback channels easy to find and monitor satisfaction.
Version History
| Version | Date | Notes |
|---|---|---|
| 2.0 | 10 Dec 2025 | Major update; clarified channels, blackout, and fair disclosure controls. |