National Refinery Limited

New CUIN Registration number 0001747 NTN-No 0711325-7

INVESTORS’ RELATIONSHIP & COMMUNICATION POLICY

Purpose

The Company respects the rights of shareholders and value relationship with them. It seeks to facilitate the effective exercise of those rights and maintenance of relationship with them by ensuring that the Company communicates effectively with its shareholders. The purpose of this policy is to promote effective communication with shareholders and encourage effective participation by shareholders at company meetings. To ensure a high quality of communication and level of clarity with all investors and other stakeholders, the Company endeavors to provide shareholders with ready and widespread access on a timely basis to matters that affect their investment in the company; communicate in a clear, accurate and easy to understand manner with investors and other stakeholders.

Avenues of Communication

The Policy is mainly based around the following three aspects of communication.

Annual Report

The Financial Report shall be made available to shareholders and other stakeholders within the time period as stipulated in the statute / regulation(s). Shareholders can elect to receive a hard copy or an electronic copy of the Annual Report. It shall be shareholders’ responsibility to notify the Company’s share registrar of changes to their contact details and, in the case of email, maintain an active email account.

Website

The Company believes that communicating with shareholders by electronic means, particularly through its website, is an efficient way of disseminating information in a timely and convenient manner. The Company’s web‐site shall maintain dedicated ‘Investor Information’ and ‘Investor Relation’ sections containing the following information, at a minimum:

  • ·   annual, half yearly and quarterly reports and all material information lodged with the securities exchange;

  • ·   shareholder’s information – providing current information relating to shareholders’ related matters;

  • ·   share registrar details;

  • ·   free-float information of Company’s shares;

  • ·   credit rating of the Company;

  • ·   notices of shareholders’ meetings and explanatory material, if any; and

  • ·   investor’s complaints.

Shareholders may, at any time, direct questions or request for information through the ‘Contact Us’ section of Company’s website (www.nrlpak.com) or in writing. The details of key contact persons may also be made available at Company’s website.

Shareholders’ Meeting

The Company regards shareholders’ meetings as key events in terms of maintaining good investor relationship and an opportunity for face-to-face communication with its shareholders.

The Company recognises the rights of shareholders and encourages the effective exercise of those rights through the following means:

  • ·  notices of meetings drafted in precise and clear language shall be distributed to shareholders in accordance with statutory requirements; and shareholders may participate in voting process on proposed resolutions personally or through proxies, if shareholders are unable to attend the meeting;

  • ·  shareholders are encouraged to use their attendance at meetings to ask relevant questions where management / directors will be present to provide appropriate responses.

Investors’ Grievances

Valuing investor relationship high, the Company has internally established a mechanism for investor services and grievances handling. The Company has hired the services of an independent Share Registrar and has a dedicated section (Shares Section) to resolve investors’ concerns.

It is the top priority of the Company to address investor’s grievances. For all shares related issues, Shareholders may contact Shares Registrar of the Company.

If Investors/Shareholders grievances are not resolved at the level of Shares Registrar, they may escalate their complaints to the Shares section of Company directly; relevant contact details of designated officials shall be made available at Company’s website.

The Company shall also comply with regulatory requirements / guidelines as issued from time to time to facilitate and address the investors’ grievances.

Review of the Policy

This policy is subject to review by the Board of Directors on need basis.