Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 SHELL REFINING COMPANY (FEDERATION OF MALAYA) BERHAD

Corporate Disclosure Guide Executive Summary 1. 2. 3. 4. 5. 6. 7. 8. 9. General Statement of Guide Guide Administration Material Information Confidential Information Disseminating Information: General Application o Communicating with Analysts & Investors o Communicating with the Media Responding to Market Rumours Forward Looking Information Electronic Communications Employee Trading

1. General Statement of Guide: 1.1 Commitment Shell Refining Company (Federation of Malaya) Berhad (the Company) is committed to provide accurate, timely, consistent and fair disclosure of corporate information to enable informed and orderly market decisions by investors. The Board of Directors approved this Guide on 16 August 2004. The Company is subject to a number of legal, listing authority and stock exchange requirements with regard to disclosure of information, especially price-sensitive information. Price-sensitive information is information which if disclosed to the public would likely affect the price of a companys shares. It is necessary to take account of these requirements in the context of investor relations, as breaches could lead to the Company or the Shell Affiliate which is the shareholder of the Company and potentially, Royal Dutch Shell plc suffering severe penalties, and could expose the individuals involved to civil or criminal liability. 1.2 Intent The intent of this Guide is to;

raise awareness about, and focus management and employees on, disclosure requirements and practices; provide guidance and structure in disseminating corporate information to, and in dealing with, investors, analysts, media representatives and the public (the investing public); ensure compliance with legal and regulatory requirements on disclosure; this Guide is also intended to protect individuals from improperly disclosing sensitive information, which can lead to prosecution under

Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 applicable securities laws.

1.3 Related Rules & Guidelines This Guide takes into consideration primarily the requirements under Malaysian law;

securities laws and regulations governing corporate disclosure and confidentiality in relation to securities listed on Bursa Malaysia Bursa Malaysia Listing Requirements Best Practices in Corporate Disclosure of Bursa Malaysia

and this Guide further takes into consideration the broader context and direction provided by;

Shells "Statement of General Business Principles", "Shell Shares Code of Conduct", Downstream-One Governance Guide and Group Governance Guide Shell Group policies relating to investor relations, group reputation and media relations protocol and Shell Malaysia Media Relations Protocol other Shell policies dealing with the classification and handling of information, electronic communications and use of the Internet

1.4 Application This Guide applies to the conduct of directors, officers, managers and employees of the Company and to all methods that the Company uses to communicate with the investing public, including, but not limited to;

written statements, Annual Reports, Interim Reports, news releases, letters to shareholders, speeches by senior management, investor presentations, e-mail messages and the Companys Internet web page; and oral statements, individual or group meetings, telephone conversations, interviews and news conferences.

1.5 Scope This Guide gives specific guidance in the following areas;

disclosing material information maintaining the confidentiality of information disseminating information communicating electronically

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employee trading

2. Guide Administration: 2.1 Corporate Disclosure Committee The Company shall put in place a Corporate Disclosure Committee (the Committee) that will oversee the Companys corporate disclosure practices and ensure implementation and adherence to this Guide. The Committees responsibilities include;

maintaining an awareness and understanding of governing disclosure rules and guidelines, including any new or pending developments ascertaining whether corporate developments constitute material information and, if so, ensuring procedures outlined in this Guide are implemented to either ensure full and timely disclosure or keep the information confidential developing and implementing procedures to regularly review, update and correct corporate disclosure information, including information on the Internet web site bringing this Guide to the attention of the Companys directors, management and staff on a regular basis monitoring for compliance with this Guide and undertaking reviews of any violations, including assessment and implementation of appropriate consequences and remedial actions reviewing this Guide at least annually and updating as necessary and appropriate to ensure compliance with prevailing rules and guidelines

The Committee includes the following members;

Director of Finance Managing Director GM, Corporate Affairs Company Secretary Finance Manager

The Finance Manager will serve as the primary contact person for the Committee and will engage other Committee members as necessary and appropriate to the matter at hand. In the event of his/her absence, any other member of the Committee can be contacted on matters referenced in this Guide. 2.2 Strategy The approved strategy is as follows:Party Schedule Substantial Shareholder (> 5% Upon request but each shareholder

Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 shareholding) shall be limited to one engagement per annum. The Company Secretary shall coordinate after verifying such shareholders holding. At least two investor briefings to be conducted per annum. Recommended to follow soon after the 2nd Quarter (interim dividend) and 4th Quarter (full year results and final dividend) results. As recommended by the Committee

Investing community (including fund manager, analysts)

Other external representations

The Committee shall review the strategy as and when required by the Board of the Company. 2.3 Spokespersons (a) General (i) Press releases and media conferences The primary authorized spokesperson responsible for communicating the Company information to the investing public is the Chairman. In the absence of the Chairman, the following persons may be the spokesperson: Managing Director Director of Finance

as approved by the Chairman. General announcements must be made in accordance with the Shell Malaysia Media Relation Protocol. The GM, Corporate Affairs and the Company Secretary to be present. (ii) Investor briefing The primary authorized spokesperson responsible for communicating the Company information to the investing public is the Director of Finance. In the absence of the Director of Finance, the following persons may be the spokesperson: Managing Director Finance Manager

as approved by the Director of Finance. The Company Secretary to be present. 4

Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 (b) Bursa Saham Announcements Primary authorized spokespersons responsible for communicating Company information for matters relating to, inter alia, compliance with the securities law and Bursa Malaysia Listing Requirements will be the; Chairman; or Company Secretary

These spokespersons may, from time to time, designate others to speak on behalf of the Company or to respond to specific inquiries, where doing so facilitates effective communication with the Bursa Malaysia or Securities Commission. Generally, however, such designations will be limited to the . Managing Director Finance Manager

The Company Secretary will seek the Independent Directors support for all Bursa Malaysia announcements. Employees other than authorized spokespersons should not respond to requests for Company information from Bursa Malaysia or Securities Commission unless specifically asked to do so by an authorized spokesperson. Any such requests should be referred to an authorized spokesperson. It is not the intent of this Guide to restrict employees from speaking at conferences or to outside parties where doing so serves the Companys business purpose. However, when doing so, employees must ensure that any Company information provided is in compliance with this Guide and should contact the Chairman or the General Counsel if in doubt about the appropriateness of supplying certain information. 2.4 Line of Business Responsibilities It is essential that the Committee and authorized spokespersons be fully informed of all Company developments that could potentially impact the disclosure process. Consequently, it is the responsibility of corporate and line of businesses in the Company to keep the Committee and spokespersons fully apprised of all significant Company developments so as to;

facilitate determinations of materiality and appropriateness and timing for public disclosure of the information, or whether the information should remain confidential ensure appropriate understandings of significant developments and updates which may be germane to ongoing communications with the investing public avoid falling into the trap of denying significant developments when, in

Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 fact, such developments are occurring Where required, the Finance Manager shall seek the views from the line of business in the Zone or at Global level and advise the Committee of such views. 3. Material Information: 3.1 Definition The Bursa Malaysia Listing Requirements provides that information is considered material, if it is reasonably expected to have a material effect on:(a) the price, value or market activity of any of the Companys securities; or (b) the decision of a holder of securities of the Company or an investor in determining his or her choice of action. The material information may include information which:(a) concerns the Companys property, business, financial conditions or prospects; (b) relates to dealings with employees, suppliers, customers and others; (c) relates to any event affecting the present or potential dilution of the righs and interests of the Companys securities; or (d) relates to any event materially affecting the size of the public holding of its securities. The Securities Industry Act 1983 further defined information to include; (a) matters of supposition and other matters that are insufficiently definite to warrant their being made known to the public; (b) matters relating to the intentions, or likely intentions, of a person (affecting the Company); (c) matters relating to negotiations or proposals with respect to commercial dealings or dealings in securities; (d) information relating to financial performance of a corporation; (e) information that a person proposes to enter into, or has previously entered into one or more transactions or agreements in relation to securities or has prepared or proposes to issue a statement relating to such securities; and (f) matters relating to the future (of the Company). In addition to the above, information that will have material change in the business that could have the same potential market effects should also be disclosed. Decisions on the materiality of information will be made within the context of the Companys overall business affairs and dimensions. Such decisions require the exercise of experienced judgment and are the responsibility of the Committee. In cases where such decisions about materiality are not clear-cut

Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 and there is doubt as to whether disclosure should be made, the Company will consult with and seek guidance from Bursa Malaysia. 3.2 Disclosure Where and when information has been determined to be material, the Company will immediately initiate a process to ensure accurate, full, true, plain and timely disclosure of such information to Bursa Malaysia and recognized news services. Disclosure to recognized news services will be made in accordance with the Shell Malaysia Communications Protocol. This will always apply except in certain circumstances where the Company may temporarily refrain from publicly disclosing material information, provided that complete confidentiality is maintained. These exceptional circumstances include:(a) when immediate disclosure would prejudice the ability of the Company to pursue its corporate objectives; (b) when the facts are in a state of flux and a more appropriate moment for disclosure is imminent; (c) where company or securities laws may restrict the extent of permissible disclosure before or during a public offering of securities or a solicitation of proxies. Informal meetings or of the records comments do not exist.

3.3 Responsibilities & Procedures 1. Shell Malaysia Corporate Affairs will prepare and issue the Companys news releases, including releases of material information, consistent with Shell Malaysia Media Relation Protocol. 2. Shell Malaysia General Counsel together with the Company Secretary shall be responsible for all Bursa Malaysia Announcements. The draft announcement will be reviewed by the Committee to ensure it is in compliance with applicable securities laws and Bursa Malaysia Listing Requirements. 3. Director of Finance will have specific responsibility to review and validate all financial data contained in news releases and will ensure that disclosures are consistent with prevailing accounting standards and guidelines. 4. Shell Malaysia Corporate Affairs will have specific responsibility to ensure that the content of the release clearly and effectively communicates the intended substance and meaning of the information to the public. 5. The Board of Directors or the Audit Committee will review all news releases

Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 containing financial information. 6. All news releases involving material information will also be reviewed and approved by the Chairman or in his absence, the Managing Director of the Company. 7. Once the content of a news release involving material information has been vetted and agreed, the Company Secretary submit such material information or where possible, will advise Bursa Malaysia in advance as to the content and planned timing for the release. After notification to Bursa Malaysia, Shell Malaysia Corporate Affairs will use a recognized wire service to disseminate the release. In addition, a copy of the news release will be made accessible on the Companys internet web site. 4. Confidential Information: 4.1 Application In restricted circumstances, the Company, in consultation with the Committee, may choose to temporarily withhold disclosure of material information where immediate or premature release of the information would be unduly detrimental to the interests of the Company. Such circumstances will be infrequent and in the necessary course of business, and justified by assessment that potential harm to the Company from immediate disclosure will outweigh potential negative consequences from delaying disclosure. In such cases, the Company will keep such information completely confidential for such limited period of time necessary to ensure that the company is not unduly prejudiced or damaged by its release. 4.2 Responsibilities & Procedures When material information is being withheld, the Company will take the following precautions to keep the information confidential;

the information will only be disclosed to the Companys Board of directors, officers, employees or advisors, the controlling shareholder and credit rating agencies in the necessary course of business, and on a need to know basis if and when the information is disclosed in the necessary course of business, recipients of such information will be educated and regularly reminded of the need to keep it confidential inside and outside the Company Confidentiality Agreements will be used to ensure protection and confidentiality of the information by third parties reasonable care will be taken to ensure appropriate security and protection of the information

Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 These responsibilities and procedures also apply during the period of time when news releases involving material information are being developed, until the information has been released and disseminated to the investing public. When the confidential material information being withheld involves a material change, the Company will file a report with Bursa Malaysia on a confidential basis, in accordance with securities legislation. If, at any time or any circumstance, confidential material information is inadvertently divulged in a way that results in selective disclosure to any individual member of the investing public, Shell Malaysia Corporate Affairs will ensure full and immediate, public disclosure and dissemination. Where the Company becomes aware of any rumour or report, true or false, that contains material information, the Company will make due inquiry and immediately publicly clarify, confirm or deny the rumuor or report (which may be by word of mouth or publication in a newspaper, newswire, magazine, a brokers market report or any other publication). 5. Disseminating Information: 5.1 General Application The following principles and practices will be applied when disseminating corporate information to the investing public;

the Company will disseminate corporate information in an equitable manner and will strive to respond in a timely manner to all legitimate requests for information material information will in all cases be disseminated broadly and publicly via recognized news services and other means the Company will not provide confidential, proprietary or material, nonpublic information to the investing public, and will deny any requests for same the Company recognizes that discussions and meetings with the investing public are an important part of the companys investor relations program. The Company will provide non-material and publicly disclosed information in individual and group discussions and meetings where doing so facilitates better understandings about the business and affairs of the company. Generally, such information will be factual and non-speculative in nature and will not in any way significantly impact, impair or be detrimental to the Companys performance and effectiveness. the Company will not discriminate or differentiate amongst recipients of non-public, non-material information and will respond in the same manner to all requests for such information. This means that the Company will provide the same information and details that it has provided to analysts or fund managers, to any other individual market

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participant or media representative, upon request. During the period from the first day of the month following each quarter until the public release of quarterly financial results, the Company will impose a "quiet period" during which it will refrain from providing any information or guidance on matters potentially impacting earnings outlooks.

5.2 Communicating with Analysts & Investors Once approved by the Chairman, one of the primary responsibilities of the Director of Finance is to communicate with financial analysts, investors and prospective investors, and to provide information about the company to them as set out in the Strategy. The Committee shall approve all materials presented in such meetings. It is the responsibility of the Finance Manager to ensure that no material, nonpublic information is included in related presentation materials or is otherwise selectively disclosed at meetings with financial analysts and investors. If material, non-public information is inadvertently disclosed at such a meeting, the Finance Manager will take immediate action to achieve broad, public dissemination of the information. Presentation materials from recent meetings with financial analysts and investors will be posted on the Companys internet web site as soon as practical after the presentation has been made. Hard copies of such presentations will also be made available to the investing public, on request. Unauthorised employees shall not discuss the Companys business and affairs with any financial analysts and investors at any time. However, if such discussions inadvertently occur, the employee is responsible for immediately advising the Finance Manager, or in his absence, a member of the Committee, about the nature and content of the discussion. The Finance Manager will then ascertain whether any material, non-public information was disclosed and, if so, will take immediate action to achieve full public disclosure. The Finance Manager will review financial analysts models and reports on request, and will solicit other Shell inputs and involvement in the review process as needed. Related feedback to analysts will be limited to comments and general guidance referring to current factual information and underlying assumptions so as to point out errors, omissions or inconsistencies vis-a-vis the public disclosure record of the Company. In communicating with analysts, the Company will not confirm or attempt to influence analysts conclusions or opinions, speculate about future business plans or activities, provide specific "bottom-line" financial expectations for the Company or express comfort with analysts models and earnings estimates. The

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Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 Company will not in any circumstance restrict or withhold information from any analyst that it has provided to others, nor will the Company pressure any financial analyst to change a recommendation or rating. The Company will not distribute financial analysts reports outside the Company, post them on its internet web-site or otherwise refer to analysts ratings or opinions in external communications or presentations. The Company. will provide a complete list of analysts known to be covering the Company to interested persons, on request. If any staff has an unplanned contact with the investor community, they should decline to comment and refer to the Finance Manager or any member of the Committee. The employees are prohibited to make any comments on any other Shell Group companies, competitors or any other third parties. 5.3 Communicating with the Media All communications with the media shall be made in accordance with the Shell Malaysia Media Relation Protocol. It is noted that the Chairman will participate in news conferences, interviews and meetings. If material, non-public information appears to have been inadvertently disclosed at such events, the Chairman will advise the members of the Committee, and where this is confirmed, immediate action will be taken to achieve full public disclosure of the information. The Company will not provide material information to the media on an exclusive or selective basis, and will not under any circumstances provide material information to the media on upcoming events or announcements before it is publicly released. 6. Responding to Market Rumours: Consistent with the Shell Groups policy to not comment, affirmatively or negatively, on market rumours or speculation, the Company spokespersons will respond consistently by saying, "It is our policy not to comment on market rumours or speculation." If, however, the Company becomes aware of a rumour about a material change, or about material information that is being withheld from public disclosure under confidentiality privileges, it will consult with Bursa Malaysia for guidance on the matter. If the Company, Bursa Malaysia, or a securities regulator feels that a statement in response to a market rumour is warranted, the Committee will consider the matter and make a recommendation to the Chairman as to the

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Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 nature, extent and timing of any Company response. Company directors, officers, employees and advisors are bound by this Guide and by other means to maintain the confidentiality of material, non-public information (see Section 4; Confidential Information). Where it becomes apparent that one of these parties is the source of a market rumour involving such information, the Committee will review the matter and recommend a course of action as to appropriate consequences and remedial measures. Where the Company becomes aware of any rumour or report, true or false, that contains material information, the Company will make due inquiry and immediately publicly clarify, confirm or deny the rumuor or report (which may be by word of mouth or publication in a newspaper, newswire, magazine, a brokers market report or any other publication). 7. Forward Looking Information: The Company will not provide forecasts of future earnings or other financial results. The Company will provide sufficient forward-looking information and guidance to the investing public to enable reasoned evaluations of the Company and its future performance prospects. Such information could include guidance and/or forecasts respecting volumes, expenses, capital expenditures, new projects, fiscal terms and market, commercial and technical considerations. Generally, such information and guidance will be consistent with and complementary to information that has been otherwise provided via timely disclosure documents such as Annual Reports, news releases, Interim Reports, etc. In no circumstance will any material forward-looking information be provided in advance of its general public disclosure. Documents containing forward-looking information will be accompanied by a disclaimer cautioning the reader that there are risks and uncertainties that could cause actual results to differ materially from what is indicated in the document. When making oral forward-looking statements, reasonable care will be taken to also include appropriate reference to such risks and uncertainties in the discussion. 8. Electronic Communications: E-mail and Internet Use Shells "Internet Policy" and "Internet E-mail Guidelines" provide rules and guidance for employees as to appropriate use of the internet. Employees are responsible and accountable for knowing these rules and guidelines, and for any and all actions they take on the internet. Shell has a security system in place to monitor employee activity on the internet. Violations of the internet policy are considered to be a serious offence and may result in disciplinary actions up to and including dismissal.

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Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 Amongst other things, Shells internet policy and e-mail guidelines specifically prohibit using internet e-mail to transmit or exchange confidential or critical company information, except where a secured method is employed. More generally, Shell considers internet information and communication to be an extension of the corporate disclosure record. As such, Shell use of the internet and e-mail is subject to the same disclosure rules, guidelines and procedures outlined in this Guide for other means of disseminating corporate information. While employees are not generally restricted from participating in internet chat rooms, they are discouraged from participating in chat room discussions about Shells securities or its business plans and results. Such discussions would be inconsistent with this Guides intent to limit authorized spokespersons and could expose employees to risks and consequences of inadvertently communicating or contributing to rumours about confidential, material information. Internet Web Site [SRC web site for public] The Company has an internet web site [ web address ] that contains information about the Company, its products and businesses, employment opportunities and other areas of interest to the public and other parties. The Companys web site also clearly distinguishes a separate "Investor Information" section containing disclosure and other company information of interest to the investing public. The "Investor Information" section of the Companys web site will contain all timely disclosure and material information documents, including;

Annual Reports Quarterly (Interim) Reports Annual Information Forms Bursa Malaysia Announcements News Releases

All timely disclosure and material information documents will be posted on the Companys web site as soon as possible after release by the news wire service. In addition, the "Investor Information" section will contain supplemental, nonmaterial information, including;

Corporate Fact Sheets Investor Relations Presentations Management Speeches Other materials that may be distributed at meetings with investors

Supplemental, non-material information will be posted on the web site as soon as practical after it is available.

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Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 Generally, documents posted in the "Investor Information" section of the Companys web site will be posted in their entirety. Any exceptions will be noted. All information posted in this section will also be made available in hard copy, on request. An e-mail link to Shell Malaysia Corporate Affairs is included in this section to facilitate requests for additional information and/or hard copies of materials. Given the potential for web based information to be assumed as real-time, "live" or always up-to-date, the Company recognizes the need for due diligence in maintaining, updating and clearly identifying the "vintage" of information on its web site. All timely disclosure and material information documents will be clearly date identified and retained on the Companys web site as part of the public disclosure record for a minimum period of 2 years. Under disclosure rules and guidelines, any changes or corrections to material Company information will be publicly released and added to this disclosure record. Supplemental, non-material information such as Investor Presentations are generally materials designed to summarize and supplement public information about the company for the benefit of investors. These materials are generally time-sensitive and any such material provided on the web site needs to be managed to ensure its currency and relevancy for investors. Supplemental, nonmaterial information such as Investor Presentations will be clearly date "stamped" and will be maintained on the web site until such time as the information becomes outdated or is replaced. The Company will only post Investor Presentations on its web site which include significant changes or differences versus other presentations already posted on the site. SM Corporate Affairs has ongoing responsibility for ensuring that information in the "Investor Information" section of the Companys web site is up-to-date. The Disclosure Guide Committee has a broader, oversight responsibility for this section of the web site to ensure that appropriate standards of care are being applied for disclosures of information via this medium. 9. Insider Trading / Employee Trading: 9.1 Application Under Securities Industry Act, a person is an insider if that person; (a) possesses information that is not generally available which on becoming generally available a reasonable person would expect it to have a material effect on the price or the value of the securities; and (b) knows or reasonably ought to know that the information is generally not available.

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Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006 Therefore, directors, officers and employees of the Company with insider knowledge of undisclosed material information, is prohibited from trading in the Companys shares until after the information has been publicly disclosed. Persons considered to be in a special relationship with Shell include;

Directors and officers of the Company Employees Persons who provide business or professional services to Shell Any other person or company informed about undisclosed material information about Shell by any of the above parties

Insider trading legislation therefore applies to, and imposes obligations on, Shell employees. Related guidance and direction on insider trading is provided for employees in Shells Shares Code of Conduct manual and related supporting documents. 9.2 Trading Restrictions An insider must not buy or sell Shell shares until a reasonable time (generally one business day) after the information has been publicly disclosed. Such persons are also prohibited from trading shares of any other company if they have received undisclosed material information as a result of their business relationship with that company or from a person in a "related party" with that company. Generally, employees are discouraged from trading in the shares of the Company or its affiliates on a short-term basis, and are encouraged to seek advice from the General Counsel or Company Secretary whenever unsure or in doubt about trading securities in certain situations. The Shell Group has subscribed that the black out periods (also known as closed periods) shall commence on the first day of the month following the quarter and end on the third business day following public release of the quarterly financial results. Officers and insider employees are required to contact the Finance Manager prior trading in the Companys shares. The Bursa Malaysia Listing Requirements have defined the closed periods as follows:(a) during the period commencing from the time information is obtained, up to one full market day after the announcement to Bursa Malaysia of a matter that involves price-sensitive information in relation to securities concerned; and (b) during the period commencing from one month prior to the targeted date of announcement to Bursa Malaysia of the quarterly results, up to one full market after the announcement of a listed issuers results for the financial quarter.

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Approved by the Board on 16 August 2004 1st Amendment on 17 August 2006

On occasion, certain employees are restricted from trading in Shell shares (even when trading windows are open) when they possess insider knowledge about pending events or developments constituting material information about the Company. Tipping Prohibition No person having inside information may recommend any other person to enter into any transaction in the Companys shares. An exception to these prohibition apply if the person concerned is acting in the ordinary course of his duties, but that exception must be interpreted in a very restrictive manner. Back to top Date: 16 August 2004 Comments or questions about Shell Refining Company (Federation of Malaya) Berhad or Shell Malaysia Web site? Please contact us at: [ web site name]

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