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Employee Trading Policy at Bitkub

Dear Team,

The Company is committed to treating all its stakeholders with transparency and fairness in accordance with internal control and insider trading principles. In order to achieve this, the Board of Directors has adopted the Employee Trading Policy. This policy is intended to: (1) Provide rules and guidelines for digital assets trading; (2) Help the Company’s directors, executives and employees to comply with the Emergency Decree on Digital Asset Businesses B.E. 2561 regarding the insider trading; and (3) Preserve stakeholders and investors confidence in internal control of the Company. All directors, executives, and employees have an individual responsibility to ensure that they comply with this Policy and the law related to insider trading, as well as communicate this Policy to their spouses (or reputed spouses) and minor children. The policy strictly prohibits all employees in all circumstances from buying or selling any digital asset or recommend that another person (such as colleagues, family or friends) buy, sell or hold a digital asset under material nonpublic information relating to Bitkub. Material nonpublic information includes new assets that will be launched or added to our platform, public offerings, promotions, etc. that is yet to be announced to the public.

To ensure a clear understanding and promote compliance, this policy was communicated to all our employees multiple times through different channels. More than sending emails, this was given emphasis during our Show & Tell meetings. It is essential for us to ensure that this message is sent across all teams and will be translated into action. The issue (at its core) has to do with public confidence and a system requiring fairness. This trading restriction and transparency which applies to all Bitkub’s personal employee trading activity on any platform remain in effect now.

I take this policy and your obligations under it very seriously as a group CEO of Bitkub and will take any disciplinary or preventive action deemed appropriate to address existing or potential violations of this policy, up to and including termination of your employment. Any employee who becomes aware of a violation of this policy should immediately report the violation to the Head of Compliance Officer.

We share a common vision to become Thailand’s most trusted financial partner and the leading cryptocurrency exchange platform. I expect everyone to uphold integrity and honesty in everything we do. This is our shared responsibility to our company, customers and the community. Our success has been and will continue to be dependent on the trust that our clients and shareholders place in us.

Thank you all.

Topp Founder and Group CEO of Bitkub


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