Related Party Transactions Policy

The Company recognizes that under the law, in order for a contract with an officer not to be voidable, the contract should be fair and reasonable under the circumstances and should have been previously authorized by the Board of Directors. The Company also recognizes that under the law, in order for a contract with a director not to be voidable, the presence of such director in the board meeting in which the contract was approved should not be necessary to constitute a quorum for such meeting, and the vote of such director should not be necessary for the approval of the contract.  The contract should also be fair and reasonable under the circumstances.  

The Company observes an arm’s length policy in its dealings with related parties.  Any transactions with affiliates and other related parties are entered into in the ordinary course of business. These transactions consist principally of sale and/or purchase of goods and/or services.  Transactions with related parties are made at normal market prices and terms.  An assessment is undertaken at each financial year by examining the financial position of the related party and the market in which the related party operates.  The Company does not enter into related party transactions that can be classified as financial assistance granted by the Company to subsidiary or affiliate entities.  Moreover, consistent with the Manual that all material information, i.e., anything that could potentially affect share price, shall be publicly disclosed, related party transactions are fully disclosed in the Company’s notes to its audited consolidated financial statements.