program basis without providing its securities for credit rating prior to the offer for sale of the securities which is in violation of the Securities and Exchange Act B.E. 2535. SEC Act S.33 Settlement

Mr. Surin Banyongponglert From 25 July 2017 to 9 August 2017 (total 11 working days), Mr. Surin Banyongponglert traded PICO shares via his 4 trading accounts on a continued basis with an intent to