Page 5

Sunway City Berhad

·  Dealings in Securities for Year 2010

/ MEMO
SUNWAY CITY GROUP OF COMPANIES

To

/ : / As per Distribution List attached / Date: 11 January 2010

From

/ : / Tan Kim Aun
/ Company Secretary
Subject / : / SUNWAY CITY BERHAD (“SUNCITY”)
·  DEALINGS IN SECURITIES FOR YEAR 2010

1. APPLICATION AND DEFINITIONS

Please be advised that Chapter 14 of the Listing Requirements of Bursa Malaysia Securities Berhad ("Bursa Securities") prohibits all Directors and Principal Officers (“affected persons”) from dealing in the securities of SunCity during the closed period.

"Principal Officers" mean the Chief Executive who is not a director, Chief Financial Officer or any other employee who has access or is privy to price-sensitive information in relation to SunCity.

“Dealing in securities” includes acquiring or disposing of the securities of SunCity (eg. shares and warrants).

"Closed period" means a period commencing 30 calendar days before the targeted date of announcement up to the date of announcement of the quarterly results to Bursa Securities.

“Price-sensitive information” means information that ‘on becoming generally available would or would tend to have a material effect on the price or value of securities’.

As such, the closed periods for trading in the securities of SunCity for year 2010 are as follows:-

Quarterly
Results / Targeted Date of Release of Quarterly Results / Closed Period / Estimated Date
Allowed for Commencement
of Trading
Quarter 2009
(31/12/2009) / 25 Feb 2010 / 26 Jan 2010 to 25 Feb 2010 / 1 Mar 2010
1st Quarter 2010
(31/03/2010) / 27 May 2010 / 27 April 2010 to 27 May 2010 / 31 May 2010
2nd Quarter 2010
(30/06/2010) / 26 Aug 2010 / 27 July 2010 to 26 Aug 2010 / 30 Aug 2010
3rd Quarter 2010
(30/09/2010) / 25 Nov 2010 / 26 Oct 2010 to 25 Nov 2010 / 26 Nov 2010

2. RESTRICTION ON DEALINGS – POSSESSION OF PRICE-SENSITIVE INFORMATION

The affected persons MUST NOT deal in the securities of SunCity as long as they are in possession of price-sensitive information, as they shall be liable for insider trading.

The affected persons who are NOT in possession of price-sensitive information relating to SunCity, may engage in dealings during a closed period provided that they comply with the procedures set out below.

3. PROCEDURE FOR DEALINGS IN SECURITIES DURING CLOSED PERIODS

Paragraph 14.08 of the Listing Requirements of Bursa Securities states that the affected persons who wish to deal in the securities of SunCity during a closed period must comply with the following procedures:-

3.1 Before the proposed dealing, the affected person must give notice of intention to deal in writing to Company Secretary.

3.2 Upon receipt of such notice, an immediate announcement must be made to Bursa Securities, stating the following information:-

(i) the affected person’s current holdings of securities in SunCity; and

(ii) the affected person’s intention to deal in the securities of SunCity during a closed period.

3.3 The proposed dealing can only be effected or commence after 1 full market day from the date of announcement made pursuant to item 3.2 above. “1 full market day” excludes the day on which an announcement is made.

3.4 The affected person must give notice of the dealing in writing to the Company Secretary within 1 full market day after the dealing has occurred and the Company Secretary must immediately announce such notice to Bursa Securities. The notice and announcement shall contain the following information:-

(i) the date on which the dealing occurred;

(ii) the consideration for the dealing; and

(iii) the number of securities involved in the dealing, both in absolute terms and as a percentage of all issued securities of that class in SunCity.

3.5 The Company Secretary must maintain a proper record of all notices received from the affected persons.

3.6 The Company Secretary must, at each board meeting, table a summary of the dealings notified since the last board meeting.

4. PROCEDURE FOR DEALINGS IN SECURITIES OUTSIDE CLOSED PERIODS

Under Paragraph 14.09 of the Listing Requirements of Bursa Securities, when the affected persons deal in the securities of SunCity outside the closed period, they must comply with the following procedures:-

4.1 The affected person must within 3 market days after the dealing has occurred, give notice of the dealing in writing to the Company Secretary who will then make an immediate announcement to Bursa Securities of such dealing. The notice and announcement shall include the information set out under item 3.4 above.

4.2 The Company Secretary must maintain a proper record of all notices received from the affected persons.

4.3 The Company Secretary must, at each board meeting, table a summary of the dealings notified since the last board meeting.

5. EXEMPTIONS FROM RESTRICTIONS ON DEALINGS IN SECURITIES

Please note that pursuant to Paragraph 14.06 of the Listing Requirements of Bursa Securities, the following categories of dealings are exempted from the above restrictions:-

(i) Acceptance or exercise of options or rights under an employee share or share option scheme.

(ii) Exercise of warrants.

(iii) Conversion of convertible securities.

(iv) Acceptance of entitlements under an issue or offer of securities, where such issue or offer is made available to all holders of a listed company’s securities or to all holders of a relevant class of its securities, on the same terms.

(v) Undertaking to accept, or the acceptance of a take-over offer.

(vi) Undertaking to accept, or the acceptance of securities as part of a merger by way of a scheme of arrangement.

Subsequent dealings in securities obtained as a result of the above dealings under items 5(i) to 5(vi), are NOT exempted from the restrictions set out under item 2 above.

6. BREACH OF THE ABOVE REQUIREMENTS

Please be further advised that pursuant to Paragraph 16.18 of the Listing Requirements of Bursa Securities, in the event of any breach of the above, Bursa Securities may, after consultation with the Securities Commission, take or impose such actions or penalties as it considers appropriate against the affected persons.

Please note accordingly.

Regards,

DISTRIBUTION LIST:

A. BOARD OF DIRECTORS

1.  Tan Sri Dato’ Seri Dr Cheah Fook Ling, AO

2.  Tan Sri Dato’ Ir Talha Bin Haji Mohd Hashim

3.  Datuk Razman M Hashim

4.  Mr Ngian Siew Siong

5.  Mr Ngeow Voon Yean

6.  Dato’ Ng Tiong Lip

7.  Datin Paduka Low Siew Moi

8.  Mr Teo Tong How

9.  Mr Tan Siak Tee

10.  Mr Lim Swe Guan

B. PRINCIPAL OFFICERS

(i) Directors of SunCity’s Subsidiaries:

1.  Puan Sri Datin Seri (Dr) Susan Cheah Seok Cheng

2.  Mr Yuen Kam Wah

3.  Ms Sarena Cheah Yean Tih

4.  Mr Richard Goh

5.  Ms Ho Nyuk Chong

6.  Dr Chong Su-Lin

7.  Dr Samuel Ong Boon Leng

8.  Dr Samuel Tay Kwan Sinn

9.  Mr Lee Weng Keng

10.  Mr Ong Pang Yen

11.  Mr Ong Ghee Bin

12.  Mr Ho Hon Sang

13.  Mr Evan Cheah Yean Shin

14.  Encik Roslan Bin Baharuddin

15.  Hajah Noraida binti Mohd Yusof

16.  Mr Wong Tong Men

17.  Mr Wong Wan Wooi

18.  Mr Goh Hai Thun

19.  Mr Geh Thuan Hooi

20.  Tuan Haji Abu Bakar Bin Mohammad

21.  Mr Yong Chin Foo

22.  Mr Lim Chin Khuan

23.  Mr Lim Lian Kheng

24.  Mr Lim Chin Huat

25.  Mr Kong Kok Leong

26.  Mr Cheah Kok Hoong

27.  Mr Beh Yen San

28.  Dato’ Beh Chun Chuan

29.  Dato’ Mohamed Bin Hamzah

30.  Mr Soo Boon Choon

31.  Puan Noraihan Binti Abdul Rahman

32.  Mr Reuben Poh Yeong Han

33.  Mr Cheah Wing Choong

34.  Dr Leong Yew Pung

35.  Dato’ Ismail bin Shahbodin

36.  Mr Yong Leng Kee

37.  Mr Chan Hoi Choy

38.  Mr Hanley Chew

39.  Ms Tan Poh Chan

40.  Ms Wai Sow Fun

41.  Puan Siti Meriam @ Mariam Binti Mohd Desa

42.  En Mohamed Nazri Bin Omar

43.  En Sazaliza Bin Zainuddin

44.  Mr Alan Tang Yew Kuen

45.  Mr Loh Hwee Long

46.  En Abdul Ghani Bin Hashim

47.  Mr Sivam A/L Rajasingam

48.  Mr Stewart Lee Hong Tat

49.  Mr Rudy Yong Yek Yeau

50.  Mr Bernard Paul

(ii) Finance Department:

1.  Ms Ch’ng Lin Ling

2.  Ms Beh Soo Ming

3.  Ms Chee Mei Keeng

4.  Mr Adron Leow

5.  Ms Yap Chong Koon

6.  Ms Lisa Lee Fing Lan

7.  Ms Chin Wai Sook

8.  Mr Bryan Tan

9.  Mr Wesley Lee

(iii) Others:

1.  Mr Lee Yu Ban

2.  Mr Yee Meng Haw

3.  Mr Denis Gruhier

4.  Mr Cirioco Publo

5.  Mr Balbeer Singh Khaira

6.  Ms How May Lynn