The Company recognizes and gives importance to the rights of shareholders by not taking any actions that violate or infringe upon shareholders' rights. It also promotes shareholders' exercise of their rights. The fundamental rights of shareholders include buying, selling, or transferring shares, sharing in the company's profits, receiving sufficient company information, attending meetings to vote at shareholder meetings to appoint or remove directors, appoint auditors, and approve special items, etc. In 2021, the Company acted as follows:

Shareholder Meeting

In 2021, the Company held its Annual General Meeting of Shareholders with the following details:

• The 2021 Annual General Meeting of Shareholders was held on Thursday, April 22, 2021, at 2:00 PM. The meeting was conducted via electronic media, broadcast from the Company's head office at 179 Bangkok City Tower, 10th Floor, South Sathorn Road, Thung Maha Mek Subdistrict, Sathorn District, Bangkok 10120. 10 shareholders attended the meeting online, and 37 shareholders gave proxies, totaling 47 shareholders with 104,672,950 shares, representing 60.06% of the total issued shares of 174,273,125 shares. This met the quorum requirement and complied with the Company's articles of association, which require at least 25 shareholders and proxy holders to attend, and the combined shares must be at least one-third of the total issued shares. The meeting was attended by the Board of Directors, including the Chairman, Directors, and Audit Committee, totaling 9 members, as well as senior executives and the Company's auditors. The Chairman of the Board presided over the meeting, conducting it fully in accordance with legal requirements. The meeting procedures were as follows:
• Before the Shareholder MeetingThe Company disseminated a letter to shareholders through the Stock Exchange of Thailand's system to inform minority shareholders of their right to propose matters for inclusion in the meeting agenda and to nominate individuals for consideration as company directors in accordance with the Company's selection process in advance of the Annual General Meeting, as per the criteria set by the Company and published on the Company's website at https://www.jubileediamond.co.th/pages/jubilee-listed-company. For the 2021 Annual General Meeting, no shareholders proposed agenda items or nominated individuals for consideration as independent directors of the Company. The meeting schedule and agenda were published to shareholders through the Stock Exchange of Thailand's information communication system and the Company's website 30 days prior to the meeting. Meeting invitations specifying the venue, date, time, agenda, and matters to be proposed to the meeting, along with details and the Board's opinions on each agenda item, were sent, accompanied by proxy forms, the annual report, and additional information for consideration. These documents were sent to all shareholders listed on the book closing date for the meeting 14 days in advance and advertised in newspapers for 3 consecutive days. Shareholders unable to attend in person were given the opportunity to exercise their voting rights by proxy, including nominating independent directors, allowing shareholders to grant proxies to vote on their behalf if they could not attend the meeting.
• On the day of the Shareholder MeetingThe Company opened the registration system at 1:00 PM, approximately one hour before the meeting. All directors, executives, and auditors attended the meeting. Before the meeting, the Secretary to the Executive Board informed the meeting of the number of attendees, both in person and by proxy, and explained the voting procedures and how to ask questions or express opinions through the DAP e-Shareholder Meeting system. The Chairman conducted the meeting according to the agenda sequence specified in the invitation letter, with no changes to the agenda order and no requests for the meeting to consider other matters not specified. The Chairman provided opportunities for clarification and discussion on each agenda item, allowing shareholders equal rights to review the Company's performance and to ask questions and express opinions. The Company recorded key points in the meeting minutes for shareholders' review. Voting to approve each agenda item was by majority, using the one-share-one-vote method, except for agenda items related to approving the annual remuneration of directors, which required a resolution passed by not less than two-thirds of the total votes of attendees with voting rights. Before voting on any agenda item, the Chairman allowed shareholders to ask for details and clarifications. The Chairman ensured open voting on each agenda item, allowing shareholders to vote for individual director appointments. If additional shareholders joined the meeting, the Company counted the number of new shareholders and shares each time. New shareholders joining during the meeting could only vote on agenda items that had not yet been voted on. The Chairman summarized the voting results for each agenda item for the meeting, stating the number of shares that voted for, against, and abstained.
• After the MeetingAfter the meeting concluded, the Company announced the meeting resolutions through the Stock Exchange of Thailand's system, providing detailed voting results and outcomes for each agenda item for interested parties. Written meeting minutes were prepared and kept. The meeting minutes were published within 14 days on the Company's website. Shareholders could watch a webcast recording of the shareholder meeting on the Company's website.

The Company has a simple structure, with no cross-shareholdings and no pyramid-style shareholding structure, to ensure that shareholders receive full returns. All shareholders are treated equally and fairly, whether they are major shareholders, minority shareholders, institutional investors, or foreign shareholders. The Company also assures shareholders that the Board of Directors and management oversee the appropriate use of shareholders' money, believing this to be a crucial factor for investor confidence in the Company. The Board of Directors is responsible for overseeing that shareholders are treated fairly and their fundamental rights are protected equally.

• Proposing agenda items and nominating individuals for appointment as directors at the Annual General Meeting of Shareholders: The Company has published a letter to shareholders through the Stock Exchange of Thailand's system, allowing minority shareholders to propose matters for inclusion as agenda items according to the Company's established criteria and published on the Company's website. This ensures that minority shareholders can elect independent directors to look after their interests.
• The Board of Directors has arranged the shareholder meeting process in a manner that supports treating all shareholders equally based on their shareholdings, with one share equaling one vote. It also provides an opportunity for shareholders who cannot attend the meeting in person to exercise their voting rights by sending Proxy Form B along with the invitation letter. The form specifies the required documents/evidence and the proxy process, allowing shareholders to accurately prepare for authorizing others to attend and vote on their behalf, thus avoiding problems for proxy holders attending the meeting.
• The Board of Directors is aware of connected transactions and carefully considers their appropriateness each time. It adheres to the regulations of the Securities and Exchange Commission and the Stock Exchange of Thailand and discloses information regarding the names and relationships of connected persons in the Annual Information Statement Form 56-1 One Report for shareholders to clearly understand.
• The Company has defined the duties and responsibilities of executives and departments. It has established regulations prohibiting directors, executives, or individuals with access to inside information from disclosing such information to outsiders or individuals who are not involved, which could cause damage to shareholders as a whole, unless it is a public disclosure in accordance with the Stock Exchange of Thailand's regulations.
• The Company requires directors and executives to report their securities holdings and any changes in their securities holdings.

Measures to prevent directors and executives from using inside information for their own or others' undue benefit

The Company will not discriminate against any particular group of shareholders. All shareholders have equal access to the Company's publicly disclosed information through various contact channels, and will be treated appropriately and receive sufficient information through the Company's disclosed channels as follows:

Phone: 02-625-1188 Ext. 3208

Website:www.jubileediamond.co.th

E-mail address:ir@jubileediamond.co.th

The company recognizes its responsibility to the environment and society, as well as all stakeholder groups, and appropriately coordinates shared benefits to ensure that all stakeholders are confident that their rights are protected and treated well. The company has clearly defined guidelines that must be followed to meet the needs of each stakeholder group, and has disseminated and encouraged the Board of Directors, management, and employees to adhere to these guidelines as policy and as principles for operation, considering them as important duties for everyone. The company has added good practices and continuously developed its treatment of stakeholders, such as by establishing policies and guidelines regarding the prevention of corruption for the company's business interests, not being involved in human rights violations, promoting efficient and cost-effective use of resources, as follows:

• Shareholders - The company conducts business with honesty and integrity, committed to developing the business based on good corporate governance principles, and achieving continuous growth that provides sustainable returns. The company respects the rights of shareholders to access information for evaluating the company's management by disclosing operating results, financial status, along with accurate supporting information within the specified timeframe, to ensure transparency and fairness for shareholders.
• Community and Environment - The company conducts business with consideration for its impact and creates sustainability in a balanced manner across all three dimensions: economy (Product), society (People), and environment (Planet), and all stakeholder groups, including good corporate governance principles.
• Customers - The company is committed to creating customer satisfaction with products that meet customer needs with good quality at reasonable prices and excellent service, conducting business ethically and fairly. Additionally, the company has a strict policy to protect customer confidential information and prioritizes customer benefits, as well as providing opportunities for customers to lodge complaints or inquire for information at all times through various channels such as Jubilee Customer Service Center at Tel. 02-625-1111, website, Instagram, Line@, and Facebook, etc.
• Trading Partners and/or Creditors - The company treats trading partners and/or creditors according to commercial terms or agreements, refraining from using dishonest methods or concealing information or facts that could harm creditors. The company has established regulations prohibiting executives or employees from demanding or accepting assets or any other dishonest benefits in trade with trading partners and/or creditors. If the company or trading partners and/or creditors discover or become aware of any dishonest acts, they will promptly jointly consider resolving the problem and find ways to prevent potential future damage. In addition, with financial institutions, the company adheres to loan conditions such as the purpose of fund usage, repayment, collateral, and other agreements. In the past, the company has never breached any agreements or conditions with financial institutions.
• Government Sector - The company adheres to practices to demonstrate its responsibility to the government sector by operating its business strictly under the provisions of laws and regulations of regulatory agencies. It also cooperates in providing complete and accurate information as requested by government agencies to demonstrate transparency, as well as to build confidence and trust.
• Competitors - The company treats competitors within the framework of fair competition rules, maintaining ethical standards in competition, not using dishonest methods to harm competitors, not seeking confidential information of trade competitors through dishonest or inappropriate means, and not committing any acts that infringe intellectual property. In the past year, the company had no disputes related to trade competitors.
• Employees - The company has clear and concrete policies regarding safety, welfare, and employee benefits. It treats the company's executives and employees equally and provides appropriate compensation. A provident fund has been established for employees to provide long-term security for employees. Additionally, the company sets policies and practices regarding the development of knowledge and potential, such as providing training and knowledge to professionalize sales employees both on-site and off-site, as well as emphasizing the development of employee personalities.

The company discloses accurate, complete, transparent, equitable, and timely information, including financial reports and business information, through the Stock Exchange of Thailand's communication channels and the company's website, www.jubileediamond.co.th, on a regular basis.

• Because the company believes that the quality of financial reports is important to shareholders and external parties, the Board of Directors ensures that the information presented in financial reports is accurate, complies with generally accepted accounting standards, and has been audited by an independent auditor. The company has appointed an Audit Committee, consisting of independent directors, to be responsible for overseeing the quality of financial reports and internal control systems. Details of the reports from the Board of Directors, the Audit Committee, and the auditor are available in the annual report.
• Investor relations activities involve communicating important and useful information to investors, shareholders, securities analysts, the media, and the general public. In 2021, investor relations activities included participating in the "Opportunity Day" event for listed companies 4 times and organizing analyst meetings 4 times.

Shareholders and investors can contact Ms. Thanaporn Thanaphapong, Corporate Secretary and Chief Financial Officer, to communicate with the company, or through email at ir@jubileediamond.co.th.

The Board of Directors plays a crucial role and has significant responsibilities in overseeing the company's operations to protect the interests of shareholders and stakeholders. This includes setting business strategies, reviewing and inspecting operations, and ensuring business activities are conducted transparently.

The Board of Directors demonstrates leadership, vision, and independence in decision-making for the ultimate benefit of the company and its shareholders as a whole. Therefore, a clear system of distinct roles and responsibilities between the Board of Directors and management is established, and the Board ensures that the company has systems in place that provide assurance that the company's activities are conducted in a legally compliant and ethical manner.

The Board of Directors consists of 9 members, comprising 3 executive directors and 6 non-executive directors. There are 6 independent directors, which is more than one-third of the total number of directors. This provides an appropriate balance to the executive directors. The Chairman of the Board is not the same person as the Chief Executive Officer and there is no blood or business relationship between them. Each director possesses diverse qualifications, including skills, experience, and specialized expertise beneficial to the company, as well as dedication and effort in performing their duties to strengthen the company's board.

1. Policies

• 1.1 Policy on the Use of Inside Information
  Directors, executives, and employees of the company are prohibited from using material inside information of the company that has not been disclosed to the public for their own benefit or the benefit of others. This includes using or disclosing information that affects the stock price when trading the company's securities. Individuals aware of such information are prohibited from trading the company's securities within 1 month before the financial statements or inside information are disclosed to the public.
• 1.2 Policy on Transparency in Information Disclosure
  The company recognizes the importance of good corporate governance under the principles of good corporate governance of the Stock Exchange of Thailand ("SET") as well as the regulations of the Securities and Exchange Commission ("SEC") and compliance with the legal framework. The company believes that an efficient, transparent, and verifiable management system will build confidence and trust among shareholders, investors, stakeholders, and all relevant parties, leading to increased value and sustainable long-term growth for the company.
  Therefore, the company must disclose information to relevant agencies within the specified timeframe. Such information must be accurate, transparent, and verifiable. This also includes information about directors and executives that the company is obliged to report according to the requirements of various agencies and laws. Individuals are responsible for reporting all information that needs to be disclosed to relevant agencies to the company completely and truthfully, and without concealing information that could affect the company's financial status and reputation.
• 1.3 Policy on Securities Holding of Directors and Executives
  Directors and executives are required to report their securities holdings, as well as those of their spouses and minor children, in accordance with the regulations of the Stock Exchange of Thailand. They must also report changes in their securities holdings to the Securities and Exchange Commission in accordance with Section 59 of the Securities and Exchange Act B.E. 2535, and submit a copy of such report to the company on the same day as the report is submitted to the Securities and Exchange Commission. Furthermore, they must report to the Board of Directors, via the Company Secretary's Office, at least 1 business day before buying, selling, or transferring securities.
• 1.4 Anti-Corruption Policy
  All directors, executives, and employees are prohibited from engaging in or accepting any form of corruption, directly or indirectly. Corruption refers to all forms of bribery, including offering or promising money, assets, or other improper and undue benefits to public officials or private entities in order to induce them to act or refrain from acting, or to obtain or retain any undue business advantages, unless such actions are permitted by law, regulations, customs, or local traditions.
• 1.5 Policy on Preventing Conflicts of Interest
  Directors and executives are prohibited from engaging in businesses, becoming partners, or holding shares in entities that operate the same business as, and/or compete with, the company, unless they have informed the shareholders' meeting prior to a resolution appointing them. In cases where the company has connected transactions, or the acquisition or disposal of significant assets, the directors and management will ensure compliance with the consideration process by holding a meeting to determine clear guidelines for assessing the appropriateness of the transaction and having the transaction reviewed by the Audit Committee. The Audit Committee will consider the transaction by prioritizing the best interests of the company and shareholders as a whole. Directors or executives with a vested interest in the matter under consideration must leave the meeting and not be involved in approving such transaction. Once the transaction is approved, directors will oversee compliance with the established procedures and disclose information through various channels to ensure that all stakeholders are fully and equally informed. Do not use opportunities or information obtained as a director, executive, or employee of the company to conduct business that competes with or is related to the company.
• 1.6 Human Rights Policy
  Personnel are an important part of the organization that will enable the company to grow stably and sustainably. The company has a policy to support both economic and social welfare, compensation benefits, and the registration of employees as insured persons under the social security law, which is in accordance with the law. The company also does not support the use of forced labor. The company's employment must be legal and fair. Everyone is treated according to human rights principles, respecting each other, and treating each other equally without discrimination based on physical or mental differences, race, nationality, religion, gender, language, age, skin color, education, social status, culture, customs, or any other matter.
• 1.7 Personal Data Protection Policy
  The company prioritizes the protection of personal data of employees, customers, and all stakeholders. In compliance with the Personal Data Protection Act B.E. 2562 (PDPA), which became effective on June 1, 2565, the company has updated and supplemented certain work processes to ensure proper processing of personal data of customers, employees, and partners. This includes controlling access and preventing the leakage of various personal data. Employees within the organization have been informed of their duties and related controls to ensure standardized practices. In cases where customers, employees, or stakeholders in the supply chain, both internal and external to the organization, have complaints or are affected by privacy violations, they can submit complaints through the Call Center or email DPO@jubileediamond.co.th

2. Responsibility Towards Stakeholders

• 2.1 Responsibility Towards Shareholders
  The company recognizes and values the rights of shareholders by not taking any actions that violate or infringe upon their rights. It also promotes shareholders' exercise of their rights. Basic shareholder rights include buying, selling, or transferring shares, sharing in the company's profits, receiving sufficient company information, having the opportunity to propose matters for inclusion in the meeting agenda, and nominating individuals for election as company directors at the annual general meeting. This also includes attending meetings to exercise voting rights at shareholders' meetings to appoint or remove directors, appoint auditors, and approve special transactions, among others.
  Furthermore, the company conducts its business honestly, transparently, and verifiably, and is committed to business development based on good corporate governance principles to ensure continuous business growth and sustainable returns. The company respects shareholders' rights to access information for evaluating the company's management by disclosing financial performance, financial position, and supporting accurate information within the timeframe stipulated by laws or relevant regulations, to ensure transparency and fairness to shareholders.
• 2.2 Responsibility Towards Employees
  The company has a policy and fair treatment for employees at all levels without discrimination, including opportunities, compensation, appointments, and transfers. It also provides adequate and appropriate welfare benefits for employees based on current circumstances. The company consistently maintains a safe working environment for the life and property of employees, alongside providing opportunities for learning and developing the knowledge and abilities of personnel in various areas to enhance their skills and work efficiency for the future development of the organization. Furthermore, all employees are instilled with the importance of complying with relevant laws and regulations, such as prohibiting the use of inside information and strictly maintaining customer confidentiality.
• 2.3 Responsibility Towards Customers
  The company is committed to creating customer satisfaction with products that meet customer needs with good quality products at reasonable prices and excellent service. It operates its business fairly and honestly, maintaining good and sustainable relationships with customers by strictly adhering to the terms and agreements with customers. Furthermore, the company has a serious policy for maintaining customer confidentiality and prioritizes customer benefits. It also provides customers with opportunities to complain or inquire at any time through various channels such as the Jubilee Customer Service Center at 02-625-1111, website, Instagram, LINE@, and Facebook, etc.
• 2.4 Responsibility Towards Competitors
  The company adheres to good competitive practices and ethics, supporting and promoting free and fair competition policies. It treats business competitors in accordance with international principles under the legal framework of trade competition practices, and does not violate or fraudulently obtain trade secrets of business partners. The company is committed to conducting business fairly by strictly adhering to the guidelines set forth in the organization's ethics. It does not intentionally perform any actions to damage the reputation of business competitors by making false accusations or using inappropriate methods.
• 2.5 Responsibility Towards Business Partners
  The company treats business partners according to agreed-upon commercial terms and agreements, equally and fairly, and based on fair returns for both parties. It has also prohibited executives or employees from demanding or accepting any property or other dishonest benefits in conducting business with partners. If the company or partners discover or become aware of any dishonest acts, they will promptly consider and solve the problem together, and seek ways to prevent future damages.
• 2.6 Responsibility Towards Creditors or Financial Institutions
  The company strictly adheres to all terms and commitments agreed upon with creditors or financial institutions, including trade terms, collateral, purpose of fund usage, debt repayment, loans, interest, and other agreements. In cases where the company is unable to comply with the terms or defaults on payments, it will promptly inform the creditors or financial institutions to jointly find solutions.
• 2.7 Responsibility Towards Society, Community, and Environment
  The company conducts its business with continuous consideration for its impact on society, community, and the environment, and to create sustainable balance across all three dimensions: economic (Product), social (People), and environmental (Planet). The company prioritizes and values the quality of life of all stakeholder groups and encourages its employees to have consciousness and responsibility towards the environment and society, including principles of good corporate governance. The company strictly adheres to laws and regulations issued by regulatory agencies.
• 2.8 Responsibility Towards Government Agencies
  The company operates its business under the strict requirements of laws and regulations of regulatory agencies. It fully cooperates in providing complete and accurate information as requested by government agencies to demonstrate transparency and build confidence and trust.

Penalties
In cases where directors, executives, and employees act improperly in a manner that creates a conflict of interest, or fail to comply with any other code of conduct as stipulated by the company, disciplinary action will be considered in accordance with the company's organizational structure and working regulations. Each department shall initially consider the matter and summarize it for submission to senior management and relevant divisions for a decision on culpability and appropriate penalties. However, if the conflict of interest is severe and causes significant damage, and cannot be resolved at the departmental level, it shall be referred to the Audit Committee for consideration, conclusion, and determination of penalties.

Penalty Determination
Penalties for directors, executives, and employees shall be determined based on the severity of the act, as follows:

1. Verbal warning
2. Written warning
3. Temporary suspension from work
4. Termination of employment without severance pay under the relevant provisions of the Labor Protection Act B.E. 2541 (and its amendments), to the extent permitted by law.
5. Legal action

This Code of Business Conduct was approved by the Board of Directors Meeting No. 1/2567 on February 21, 2567, and shall be effective from March 1, 2567, onwards.