OTTO MARINE LTD 
By (Company Registration Number 197902647M)
(Incorporated with limited liability in the Republic of Singapore on 5 September 1979)
RESPONSE TO SGX'S QUERIES REGARDING TRADING ACTIVITYIn response to the query from Singapore Exchange Securities Trading Limited ("SGX") dated 20 April 2012, the Board of Directors of Otto Marine Limited (the "Company") wishes to provide the information as set out below:
Query
Rule 1207(19)(b) of the Listing Manual requires disclosure in
the Annual Report on whether and how an issuer has complied
with the following best practice of dealing in
securities:
"An officer should not deal in his company's securities on
short-term considerations".
Please confirm whether, and if so please state how, the
Company has complied with the said best practice.
Taking into consideration the SGX Best Practices Guide, the
Company has issued guidelines to its directors and employees
regulating dealings in the Company's securities
("Guidelines"). These Guidelines include prohibiting trading
(i) on short-term considerations, (ii) while in possession of
material unpublished price-sensitive information, (iii)
during the period commencing two weeks before the release of
the Company's results for the first three quarters and, one
month before the release of the Company's full-year results
("Blackout Period").
In addition, two weeks before the release of the Company's
results for the first three quarters and one month before the
release of the Company's full-year results, an email is sent
to the Company's directors and employees reminding them of
the Blackout Period for dealing in the Company's securities
and reiterating the Company's Guidelines.
By Order of the Board
Marjorie Wee
Company Secretary
24 April 2012
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