Shareholder Policy

Privacy Policy for Shareholders and Investors

Jubilee Enterprise Public Company Limited (the “Company”) assures its shareholders, investors, and/or any person interested in the Company’s investment (“you”) that all of your personal data is of utmost importance to the Company. The Company guarantees to protect and process personal data with the most appropriate security measures. The Company aims to inform you, as shareholders investing in the Company’s shares, and investors or any person who inquires about the Company about this Privacy Policy for Shareholders and Investors (“Privacy Policy”), which specifies the necessity of collecting, compiling, processing, using, disclosing or forwarding your personal data that the Company is required to do in order to perform its duties as a Company towards you, as shareholders and investors, in accordance with the law, namely the Public Limited Companies Act and the Civil and Commercial Code. If you do not agree to the Company’s processing of your personal data according to the terms and conditions specified in this Policy, the Company hereby informs you that the Company will not be able to perform its duties towards you.

Personal data processed

Basically, your personal data as an investor, shareholder and/or person interested in the Company's investment that the Company may need to process is divided into 2 main categories: (1) general personal data and (2) sensitive personal data. The Company aims to limit the processing of both types of personal data, especially sensitive personal data, to only the necessary level.

“Personal Data” means information about each investor, shareholder, and/or person interested in the Company's investment that allows the identification of that person, whether it is information that the Company may obtain directly from you providing information to the Company or from checking the Company's shareholder register, which the Company is required to collect and compile by law. This may include cases where the Company may receive information about you in the shareholder register from the Thailand Securities Depository Co., Ltd., which provides securities registrar services to the Company.

The Company is required to collect, compile and use the following personal data:

1. General information about you as a shareholder, namely, your name, surname, nationality, occupation, current address, number of shares held, your bank account information, national identification number, email address, and contact number.
2. In the event that you are a major shareholder as defined in the criteria of the regulatory agencies, including but not limited to the Securities and Exchange Commission and the Stock Exchange of Thailand, the Company is required to collect additional personal information about you, including your history (including educational history, work experience, etc.) and photographs of you or representatives of the shareholders of such juristic persons.
3. General information about you as a shareholder, investor and other person interested in the Company's investments that you may provide to the Company during any communications or conversations you may have with the Company through investor relations channels, which may include, but is not limited to, your first and last name, nationality, occupation, address and contact information (including telephone number and/or email address).
4. Meeting attendance information where the said shareholder participates in the shareholder meeting, which may include meeting registration information, which may include information of proxy holders representing the shareholder, along with video and audio recordings during the meeting, both in online and offline meeting formats.
5. Other personal data that you may consent to and submit to the Company for processing for other specific purposes.
   
   In the case where a shareholder holding shares in the name of a juristic person is required by the Company to collect information and use information of the Company's directors, or in the case where a shareholder has authorized another person to attend a meeting and exercise their shareholder rights under their law, the Company is required to process such person's information, which is considered processing for you as a shareholder. In such case, if you submit personal information of such other person to the Company, the Company will assume that you have provided a guarantee that you have obtained consent or have the right to disclose such person's personal information to the Company.

Purpose of collecting personal data

The Company collects and uses your personal data for various purposes, including the following purposes:

To perform the Company's legal duties towards you in accordance with your shareholder rights.

For example, managing the company (e.g., starting a new business, increasing or decreasing capital, restructuring the business, changing registered details), sending meeting invitations or other notices to inform shareholders of their rights under the law, such as the invitation to the Company's general meeting of shareholders, or sending the Company's business report to shareholders in accordance with their rights under relevant laws, including the distribution and sale of dividends to related and eligible shareholders, preparing accounts and reports, examining legal documents, and various legal duties of being a public limited company and a company listed on the Stock Exchange of Thailand. In order to carry out the rights and duties to the aforementioned shareholders, the Company is required to confirm the identity of you or your attorney or proxy in demonstrating your rights as a shareholder to exercise various rights, such as the right to attend meetings or the right to transfer shares.

Managing the response to communications you send to the company

For example, to inform or publicize various news and information regarding the Company's management that may be directly related to your investment and shareholder status, to communicate and answer your inquiries, to manage complaints, to exercise shareholder rights, or to provide various opinions, etc.

For the legitimate interests of the Company or of another person.

For example, the management of the company in analyzing the shareholder structure, recording the organization and administration of meetings, such as registration for meetings, recording votes, recording audio and/or video during meetings for the purpose of publishing the meetings via the company's website and other communication channels, which are considered actions taken for legitimate interests to ensure the transparency and good governance of the company, including for the benefit of shareholders, etc. Data analysis, conducting activities and facilitating shareholders in the event of other special events that the company may organize for you as a shareholder, risk management and internal control of the organization, supervision and auditing, including internal audits, including the exercise of legal claims.

Especially in the case of major shareholders

As defined, for the purpose of preparing the Company's annual report documents as the Company is required to prepare and may have to submit to relevant agencies or disclose to the public in accordance with the terms and conditions stipulated by relevant laws, which may include disclosing your information via the Company's website, performing duties in accordance with laws, announcements, regulations or orders of agencies, especially regulatory agencies or officials with duties and authority under the law, including judgments of any other courts that the Company may be required to act correctly and completely, including but not limited to the Securities and Exchange Commission, the Stock Exchange of Thailand, the Ministry of Commerce or other agencies.

Period of processing of your personal data

The Company is required to process and collect your personal data for the purposes stated above as necessary.

(i) in response to communications from you as an investor or any other person contacting the Company or

(ii) for as long as you remain a shareholder of the Company and the Company is still legally obligated to you; or

(iii) for any period that the Company may be obligated under other laws to retain your personal data. In addition, for the purpose of verifying and protecting the rights of the Company and you under the status of the Company and shareholders, the Company reserves the right to retain the personal data of shareholders for an appropriate period of time in accordance with the appropriate statute of limitations after you cease to be a shareholder, in the event that you may have any claims that you may have against the Company. In such event, the Company will retain your data for a period that may be expected under the collection standards (e.g., the general statute of limitations of up to 10 years).

Disclosure of personal information

Personal data you provide to the Company will be kept confidential. However, in some cases, your personal data may need to be disclosed to the following groups of individuals: external service providers who assist the Company in conducting its business and performing its legal obligations to shareholders, including protecting the Company's lawful rights. This includes, but is not limited to, Thailand Securities Depository Co., Ltd. as the Company's securities registrar; legal advisors, accounting advisors, and other advisors; and internal and external audit agencies. The Company will only disclose your personal data in accordance with the specified data processing objectives and on a necessary basis. In cases where the Company is required by law, or subject to a judgment or order from a government agency, the Company may be required to disclose your personal data to such agencies to comply with its legal obligations. The Company will only do so to the extent necessary for such obligations. In some cases, the Company may be required to disclose its annual report, which may include personal data of major shareholders of the Company, to enter into a contract or to coordinate with the Company's counterparties. The Company may be required to disclose your personal data to such counterparties. The Company will proceed under the principle of its legitimate interests and will proceed only to the extent necessary without unreasonably prejudicing the rights of the data subject; and other agencies to which you have expressly consented.

Assurance of implementation of appropriate data security measures

The Company has in place appropriate security measures to protect against unauthorized or unauthorized access, use, alteration, modification, or disclosure of personal data. In addition, the Company has established internal guidelines to determine the rights of personal data owners to access or use personal data in order to maintain the confidentiality and security of the data. The Company will periodically review such measures to ensure their appropriateness in line with industry standards and compliance with relevant laws.

Data subject rights

The Company acknowledges and respects your legal rights as a shareholder regarding your personal data under its control, in accordance with the following legal rights provisions: The right to access and request a copy of your personal data, including the right to request correction of your personal data to ensure it is current and accurate; The right to request personal data in the event that the Company makes such personal data available in a format that is easily readable or usable by automated tools or devices, including the right to request that such data be sent or transferred to another personal data controller; The right to object to the processing of your personal data; The right to request that your personal data be deleted, destroyed, or anonymized when the data is no longer necessary or when the data subject withdraws consent; The right to request that the use of your personal data be suspended when the data is required to be deleted or when the data is no longer necessary; The right to withdraw consent to the processing of data previously provided by users for the purposes specified. You may contact the Company to exercise these rights using the contact details provided by the Company. The Company will consider and notify the outcome of requests from shareholders, investors, and/or those interested in investing in the Company within a reasonable timeframe under the law by emailing DPO@jubileediamond.co.th. Or contact the head office of Jubilee Enterprise Public Company Limited, No. 179, Bangkok City Tower Building, 10th Floor, South Sathorn Road, Thung Maha Mek Subdistrict, Sathorn District, Bangkok 10120. You can also contact the company via Call Center at 02-625-1111, Monday-Friday, 9:00 a.m. - 6:00 p.m.

Amendments to this policy

The Company may update this Policy from time to time to comply with applicable practices and laws or regulations. The Company will notify you of any changes by posting the updated Policy to you through the Company's various communication channels.

Last edited: May 26, 2022