Dealing in Securities Transactions

China Uptown has issued policies on dealing in the Company's shares by the directors and the relevant employees of the Group. The policies are modeled on terms no less exacting than the Model Code for Securities Transactions by Directors of Listed Issuers in Appendix 10 of the Listing Rules. The policies set out the implications of insider dealings in the Company's shares and include guidance to directors and employees on dealing in the Company's shares.