With regard to the queries raised by the Singapore Exchange Securities Trading Limited in its letter dated 19 April 2004 in relation to the Company's Annual Report, the Board of Directors of the Company wishes to respond as follows:
Question 1 - We note from your announcement of 2 March 2004 that there were no transactions of S$100,000 or above which were transacted during the financial year under the Company's mandate for interested person transactions. Please note that Rule 907 of the Listing Manual also requires issuers to disclose the aggregate value of all interested person transactions transacted during FY03 (excluding transactions less than $100,000 and transactions conducted under shareholders' mandate pursuant to Rule 920) in the format provided in this Rule. In this regard, please provide the outstanding information required by Rule 907 (since the Company's listing on SGX). If none, please give a negative statement.
Please see answer to question 2.
Question 2 - We refer to page 60 of your Annual Report relating to disclosures on related party transactions. Please clarify whether the transactions disclosed under the heading "Related parties" are interested person transactions (as defined under Chapter 9). In your reply, please also provide the basis of your opinion. If these are interested person transactions, please state whether they are transactions covered under Rule 907, and if covered under Rule 907, clarify how rule 907 has been complied with.
The transactions disclosed under the heading "Related parties" on page 60 of the Annual Report are interested person transactions as they are inter-company transactions. Pursuant to Rule 907, we set out the following details:
Name of interested person | Aggregate value of all interested person transactions during the financial year under review (excluding transactions less than $100,000 and transactions conducted under shareholders' mandate pursuant to Rule 920) | Aggregate value of all interested person transactions conducted under shareholders' mandate pursuant to Rule 920 (excluding transactions less than S$100,000) |
Kingsmen Korea Limited |
$112,232 |
- |
Kingsmen International Pte Ltd |
$129,347 |
- |