CORPORATE DISCLOSURE POLICY

1. Introduction

The Corporate Disclosure Policy (“this Policy’) of Prodigynet Solutions Group of Companies, their subsidiaries, and affiliates set out the requirements for disclosure including the quality of disclosure to provide shareholders, stakeholders, and the public with comprehensive, accurate, and quality information on a timely basis. It outlines the Group’s approach towards the determination and dissemination of material information, the circumstances under which the confidentiality of information will be maintained, and restrictions on insider trading. It also provides guidelines in order to achieve consistent disclosure practices across the Group.

2. Objective

This Policy aims to achieve the following objectives:

a. To promote and demonstrate a high standard of integrity and transparency through timely, accurate, quality, and complete disclosure of material information.

b. To build good investor relations with the shareholders and investing public.

3. Designated Spokesperson

The following designated Spokespersons for overseeing and coordinating the disclosure of material information. The list of the designated Spokespersons is as follows:-

a. Chairman

b. Managing Director

c. any person who is authorized by the Chairman or Managing Director or the Board

4. Mode of Disclosure

The Company makes use of a brand of a communication channel to disseminate information regarding the Group, which includes electronic facilities provided by Bursa Malaysia, press releases, a corporate website, email, general meetings, and other briefing materials.

5. Principle of Disclosure Control

The Company has adopted the following principles and procedures to bridge and enhance the relationship with the shareholders and investing public:

5.1 Immediate disclosure of Material Information

Any material information that is reasonably expected to have a material effect on the price value or market activity of the shares or the investors’ decision making, must be announced immediately to Bursa Malaysia.

5.2 Withholding of Material information and maintaining confidentially.

Material information may be kept confidential temporarily if the immediate disclosure would prejudice the ability of the Company to pursue its corporate objectives. In such a case, the Company must ensure that the confidential information is securely held to prevent leakage.

5.3 Restriction of Insider Trading

Directors or Employees who possess undisclosed material information are prohibited from dealing directly or indirectly in the Company’s securities unless the information has been publicly disclosed at least one full market day from the date of the announcement of material information.

5.4 Unusual Market Activity (‘UMA”)

Directors or Employees who possess undisclosed material information are prohibited from dealing directly or indirectly in the Company’s securities unless the information has been publicly disclosed at least one full market day from the date of the announcement of material information.

5.5 Market Speculation or Rumour

As a general rule, the Company will not comment on any market speculation or rumor unless otherwise decided by the Board or as required by Bursa Malaysia.

5.6 Company & Website

The Company’s website, www. provides an avenue for the shareholders and the investing public to access information pertaining to the Group’s profile, business, and investor updates. The Company must ensure that its website is regularly updated with its latest disclosures.

6. Periodic Disclosure

The quarterly interim financial results are prepared in a format that is in compliance with the Listing Requirements and is announced to Bursa Malaysia after approval by the Board. The Circular to shareholders (if applicable) will be printed and distributed to shareholders at stipulated timeframe required under Listing Requirements.

7. Review of Policy

This Policy shall be reviewed by the Board as and when necessary and may be amended as the Board may deem appropriate.