A. Pharaon & Partners Law Firm.

The Capital Market Authority (CMA) of Saudi Arabia announced today that a final decision was issued by the Appeal Panel confirming the ruling of the Committee for the Resolution of Securities Disputes (the Committee) in the case against the previous chairman of Qassim Agriculture Co., Mr. Mohammad Saleh Suleiman Al-Rashoudi for violations of insider trading rules.

According to the ruling, Al-Rashoudi obtained inside information while serving as chairman of Qassim Agriculture Co. and traded based on such information violating Article 50/a of the Capital Market Law and Article 6 of the Market Conduct Regulations. The punishment imposed is a fine of SR 100,000 and to prevent him from working for listed companies for a period of three years.

Article 50/a of the Capital Market Law states as follows:

“a. Any person who obtains, through family, business or contractual relationship, inside information (hereinafter an “insider”) is prohibited from directly or indirectly trading in the Security related to such information, or to disclose such information to another person with the expectation that such person will trade in such Security.

Insider information means information obtained by the insider and which is not available to the general public, has not been disclosed, and such information is of the type that a normal person would realize that in view of the nature and content of this information, its release and availability would have a material effect on the price or value of a Security related to such information, and the insider knows that such information is not generally available and that, if it were available, it would have a material effect on the price or value of such Security.”

Article 6 of the Market Conduct Regulations regarding Prohibition of insider trading states that:

“a. An insider is prohibited from engaging in insider trading.

b. A person who is not insider is prohibited from engaging in insider trading if he obtains the inside information from another person and he knows or should have known, that the information is inside information.”