Legal Basis

• Circular No. 96/2020/TT-BTC issued by the Ministry of Finance of Vietnam on 16 November 2020, providing guidance on information disclosure in the securities market;

• Official Letter No. 5876/UBCK-VP dated 25 August 2023 issued by the State Securities Commission of Vietnam regarding the implementation of measures to monitor and control reporting and information disclosure obligations prior to transactions by insiders and related persons of insiders of organizations listed or registered for trading on the UPCoM, Ho Chi Minh Stock Exchange, and Hanoi Stock Exchange.

To ensure that your transactions are conducted smoothly, efficiently, and in compliance with the requirements of the State Securities Commission of Vietnam, SBS respectfully requests that clients subject to mandatory information disclosure obligations (including insiders and related persons of insiders associated with the relevant trading securities) comply with the reporting and disclosure requirements in accordance with Circular No. 96/2020/TT-BTC.

At the same time, clients are kindly requested to provide SBS with confirmation that the disclosure obligation has been fulfilled (i.e., the disclosure content must be published by the relevant Stock Exchange on its official website) prior to executing any transaction through SBS.

SBS would like to draw your attention to several important requirements regarding reporting and disclosure obligations as follows:

1. Disclosure Thresholds for Insiders and Related Persons

Insiders and their related persons are required to report and disclose information before and after transactions to the State Securities Commission of Vietnam and the relevant Stock Exchange when:

• The expected transaction value within a day is VND 50 million or more, or

• The expected transaction value within a month is VND 200 million or more, calculated based on par value (applicable to shares, convertible bonds, and fund certificates).

2. Pre-Transaction Disclosure Requirement

At least 03 working days prior to the intended transaction date, insiders and their related persons must disclose information regarding the planned transaction in accordance with the prescribed templates in Appendix XIII or Appendix XIV attached to Circular No. 96/2020/TT-BTC.

3. Transaction Execution Period

The transaction execution period must not exceed 30 days from the date of transaction registration.

Insiders and related persons must execute transactions in accordance with the timeline, volume, and value disclosed by the Stock Exchange. The first transaction may only be conducted on the trading day immediately following the disclosure by the Stock Exchange.

4. Restrictions on Simultaneous Buy and Sell Orders

Insiders and related persons may not simultaneously register and execute buy and sell transactions for the same securities during a single registration period. This restriction applies to:

• Shares

• Share purchase rights

• Convertible bonds

• Convertible bond purchase rights

• Fund certificates

• Fund certificate purchase rights

• Covered warrants

A new transaction registration may only be submitted after the completion report for the previous transaction has been filed.

Exception:
This restriction does not apply where a fund management company or a foreign fund management company’s branch in Vietnam, acting as a related person of an insider, conducts buy and sell transactions on behalf of ETF funds or entrusted client portfolios, provided that each entrusted client does not simultaneously register buy and sell transactions within the same registration period.

5. Post-Transaction Reporting

Within 05 working days from:

• the completion of the transaction (if completed earlier than the registered period), or

• the end of the registered transaction period,

insiders and related persons must disclose the transaction results and provide an explanation for any failure to execute the transaction or failure to complete the registered volume, if applicable.

Such disclosure must follow the templates specified in Appendix XV or Appendix XVI attached to Circular No. 96/2020/TT-BTC.

(For further details, please refer to Article 33 of Circular 96/2020/TT-BTC.)

SBS sincerely appreciates your cooperation in providing confirmation of the completion of reporting and disclosure obligations in order to ensure efficient and compliant trading activities at SBS.

For further information or clarification, please contact your Account Manager or the Customer Service Hotline: (028) 62 68 68 68.