POLICY FOR DEALINGS IN THE SHARES, WARRANTS, AND OTHER DERIVATIVE INSTRUMENTS OF THE COMPANY BY DIRECTORS AND EMPLOYEES

This policy is applicable to all directors and employees who are insiders for the purposes of dealings in the shares, warrants, and other derivative instruments of the Company or any of its listed subsidiaries.

An insider is anybody who has inside information:

• through being a director, employee or shareholder of the Holding Company to which the inside information relates, or having access to such information by virtue of such employment; office or profession; or
• where such individual knows that the direct or indirect source of the information was a person contemplated above.

Inside information means specific or precise information that has not been made public and -

• is obtained or learned as an insider; and
• if it were made public would be likely to have a material effect on the price or value of the Company's shares.

Deemed insiders include directors, executive officers, and other employees.

Directors, executive officers, and other employees are not permitted to deal in warrants and other derivative instruments of the holding company's shares at any time.

In respect of share purchases or sales, insiders will be required to notify the Managing Secretary, via telephone, fax or email, regarding their intention to deal in PSS shares, whether directly or indirectly. In addition, executive directors intending to deal in PSS shares or to exercise share options will be required to obtain written clearance from the Chairman of the Remuneration Committee or his authorized deputy.

The Managing Secretary will notify the insider if the deal is in a prohibited period being:

• a black-out period (the period from the end of a quarter up to and including the date on which PSS's results are publicly released); or
• any period, determined by the Executive Committee, during which the information, if it were made public, would be likely to have a material effect on the price or value of the Holding Company's shares.

Once the transaction has been completed, the insider will be required to record the complete details of the transaction, and submit it to the Managing Secretary. The Managing Secretary will ensure that such transactions are reported at the next board meeting, after which the document will be filed in the holding company's confidential records.