the joint venture agreement between GLOBAL and SCG Distribution Company Limited, a wholly owned subsidiary of the Siam Cement Public Company Limited. Mr. Surasak used such non-public information

. Mr. Surasak used non-public information concerning the joint venture agreement between GLOBAL and SCG Distribution Company Limited, a wholly owned subsidiary of the Siam Cement Public Company Limited

autoclaved aerated concrete business – including raw materials, licenses, trademarks and inventories – to Siam City Cement Public Company Limited (SCCC). Mr. Khumsup Lochaya, who at the time was a former