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Insider Trading Policy

 
It shall be policy of Anchor Land Holdings, Inc. (“ALHI”) to prohibit the trading of securities involving the persons (the “Covered Person”) and under the circumstances stated in Article 27 of the Securities Regulation Code during the following periods:
 
·         For Structured Reports/Disclosures
 
Ten (10) trading days before and three (3) trading days after the disclosure of any ALHI financial report/information.
 
·         For Unstructured Disclosures
 
Three (3) trading days before and three (3) trading days after the disclosure of any report or information other than that classified above.
 
Provided, the securities contemplated herein cover not only those which the Covered Persons have direct ownership but may extend to those which these persons have beneficial ownership over, such as those:
 
1.       Held by members of a Covered Person’s immediate family, who are living in the same household as that of the former;
2.       Held by a partnership of which a Covered Person is a general partner;
3.       Held by a corporation of which a Covered Person is a controlling stockholder; and
4.       Subject of any contract or agreement which gives a Covered Person voting or investing powers with respect to such securities.
 
In case of doubt, all Covered Persons shall consult the Company, prior to transacting its securities, in order to determine whether or not the trade will violate this policy.
 
Exception: This prohibition shall not apply to the exercise of vested stock options, i.e., the exercise of said option may be done by any person at any time, even during the periods mentioned above. However, the liquidation, i.e., the sale of shares acquired from options, shall be subject to the observance of the prohibited periods.
 
NON-COMPLIANCE
 
Any violation of this policy shall be subject to disciplinary action pursuant to ALHI’s Code of Conduct, without prejudice to any civil, criminal or administrative action which ALHI or any regulators may file pursuant to existing laws.