116 STRATEGICALLY ADVANCING (ii) during the period commencing one month before the announcement of ESR-REIT’s half year and full year financial results, and ending on the date of the announcement of the relevant results (together with (i) above, the “Black-out Period”); and (iii) at any time whilst in possession of undisclosed material or price-sensitive information. The above restrictions in dealing in ESR-REIT units also apply to the employees of ESR Property Services Pte. Ltd. Prior to the commencement of each Black-out Period, an email would be sent to all Directors and employees to inform them of the duration of the Black-out Period and remind them not to trade during this period or whenever they are in possession of undisclosed material information. The SFA requires each Director to give notice to the Manager of any changes in the number of ESR-REIT units which he/she holds, or in which he/she has an interest, within two business days after the occurrence of the event giving rise to changes in the number of ESR-REIT units which he/she holds, or in which he/she has an interest, as applicable. All dealings in ESR-REIT units by the Directors are to be announced on the SGXNet. In addition, any changes to Manager’s holdings in ESRREIT units will be announced on the SGXNet within one business day after the date on which it acquires or disposes of any such units. REVIEW PROCEDURES FOR INTERESTED PARTY TRANSACTIONS (“IPTS”) The Manager has established an internal control system to ensure that all transactions involving the Trustee and any related party of the Manager or ESR-REIT are undertaken on an arm’s length basis with normal commercial terms, are not prejudicial to the interests of ESR-REIT and the Unitholders, and are in accordance with the applicable guidelines that may be prescribed from time to time. In respect of such transactions, the Manager must demonstrate to the ARCC that such transactions satisfy the foregoing criteria, which may entail obtaining (where practicable) quotations from parties unrelated to the Manager, or obtaining one or more valuations from independent valuers, in accordance with the Property Funds Appendix. performance for FY2024. The Board has set a strategic direction in ensuring good corporate governance, prudent financial management, fair employment practices and efficient utilisation of resources. The Manager believes in the importance of integrating sustainability into its business strategies and operations in delivering stable and long-term value for its stakeholders and Unitholders. The Manager has identified the following as ESR-REIT’s key stakeholders: Investment Community, Board of Directors/BSC, Government Agencies and Industry Organisations, Existing and Potential Tenants, Local Communities, Management Team and Employees. For FY2024, the Manager’s strategy is to continue to ensure active engagement and frequent communication with the relevant stakeholders through the various engagement channels including meetings, industry forums and dialogues, general meetings and announcements, investor conferences, feedback channels, site visits and orientation and training programs. The area of focus is to understand the stakeholders’ concerns and issues which are of relevance to the material ESG factors. More information on how the Manager engages with its material stakeholder groups and to manage its relationships are set out on pages 131 to 132 of the Annual Report. The Manager is committed to upholding ESR-REIT’s sustainability practices and creating value for its stakeholders. Stakeholders can access ESR-REIT’s Sustainability Report on ESR-REIT’s website under the “Investor Relations” link. DEALINGS IN SECURITIES In compliance with Rule 1207(19) of the Listing Manual, the Manager has established a Policy on Dealing in Securities, setting out the guidelines for dealing in ESR-REIT units by the Directors and employees of the Manager. The Directors and employees of the Manager are discouraged from dealing in ESR-REIT units on short-term considerations. They are also expected to observe the insider trading laws at all times and are strictly prohibited to deal in ESR-REIT units in the following instances: (i) during the period commencing two weeks prior to the announcement of ESR-REIT’s business updates for the first and third quarter of the financial year, and ending on the date of the announcement of the relevant business updates;
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