Objective

The objective of this code of conduct is to build moral principle, rule and legal compliance to concerned executives and employees regarding confidentiality of financial statements and other related information

Scope

this Code of Conduct is an addition, not to replace the Code of Conduct of the Company’s employees, and information disclosure and transparency policy (both subjects shown in the CG policy on the website). This Code of Conduct is applied to the Board of Directors, concerned directors, and employees of PROEN Corp Public Co., Ltd., as well as anyone related to the information disclosed by IR officers and related activities.

Code of Conduct

Executives and employees who are involved with the information disclosure of IR officers must abide by the following. To participate and promote appropriate behavior, including appropriate management concerning personal conflict of interest and which occurred when performing their duties. The information must be immediately disclosed to the CEO and/or the top executives of the supervisory and audit department for significant transactions and relations that may cause a conflict of interest. To perform their duties with professional integrity based on the principle of equality, without discrimination under bribery, that is personal intensive and favors personal benefits rather than the company and stakeholders’ benefits. IR officers must comply with policies and the employee’s code of conduct specified by the listed companies. The disclosed information must be accurate, equal, and fair. All related parties are allowed to access information and make inquiries. The important and necessary information must be correctly and sufficiently disclosed in a timely manner, such as reports, documents that banks or the company group submit to the SEC and the Stock Exchange of Thailand or any other official agencies, or general communication operated by the Company. To comply with government laws and various official agency’s rules and regulations, to keep confidential information of the company, and must not use inside information for personal interest or third-party interest. Any violation of the Code of conduct or any issue that may affect the correction of the financial statements (in case of information disclosed to analysts) must be instantly reported to the Chairman of the Audit Committee (without whistleblower name if desired). In case of disclosing policy information that is deemed as “Inside information”, in accordance with Guidelines on Disclosure of Inside Information of the Securities and Exchange Commission’s notification no. KoLoTor PhoSo(Wo) 5/2018, authorized Executive Vice President, Finance and Accounting, to disclose significant inside information. Executive Vice President, Finance and Accounting, IR and central administration Director, and IR Manager are authorized to disclose the fact regarding changes in industry with clear evidence, and the information disclosed through SET and/or the Company’s website. In case of disclosing significant information that may affect the changes in the Company's securities prices, authorized the President, Secretary, and Deputy Director, Public Relations and/or assign a power of attorney to disclose information from time to time by written notice. Employees in IR and central administrative department and/or employees concern with financial and accounting and/or other employees, including the company directors are not allow to buy/sell the Company’s securities “from the last day of each quarter or the last day of financial period of the Company (depending on the case) to the date when financial statements or internal information are made public for a period of 24 hours, as well as other a blackout period determined by the Company from time to time”. They must continue to study and improve the efficiency of work, supervision and audit of the Company, and must take the necessary actions to enforce this code. Any employee who violates this Code will be subject to disciplinary action, which includes a dismissal. Violations of this Code may be considered as a violation of the law and can lead to criminal and civil penalties.

“Executives and IR officers are not allowed to make an appointment with or answer questions regarding operating results in the near future for investors and analysts for at least 10 working days prior to the turnover announcement date.”