TRADING POLICY AND GUIDELINES

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1 TRADING POLICY AND GUIDELINES July 2015

2 1. Application of the Policy Introduction This Policy has been designed to prevent improper trading by employees, senior managers and directors of NZX Limited ( NZX ) and its subsidiaries who, by virtue of their position, may have access to material information regarding NZX or an issuer of securities quoted on a market operated by NZX or about any security quoted on the markets operated by NZX. Types of transactions covered by this Policy The policy covers a Restricted Trade which is: A trade by any senior manager or employee of NZX or its subsidiaries of the following: Any security issued by NZX or an NZX subsidiary; or Any security issued by a company that is listed on a market operated by NZX; or Any security quoted for trading on a market operated by NZX or its subsidiaries; A trade by any director of NZX of any quoted security issued by NZX; and A trade by any director of an NZX subsidiary of any quoted security of that subsidiary. In this Policy: Director is a director of NZX or its subsidiaries. For the purposes of this Policy, a director of NZX will remain subject to this policy, and will deemed to remain a Director for the purposes of this Policy, until the later of: (a) three months following effective date of resignation; and (b) the day following the next public release of NZX s half year results or full year results; Security includes debt securities, equity securities, managed investment products and derivatives quoted for trading on NZX or any other registered securities market in Australia or New Zealand; Senior manager is a direct report to the NZX CEO; and Trade includes buying or selling securities, or agreeing to do so, whether as principal or agent, but it does not include subscription for, or the issue of, new securities. Note that a Restricted Trade may include a trade by trusts and companies controlled by an employee, senior manager or director of NZX or its subsidiaries. In this respect, control is not to be construed in a technical way but by looking at how decisions are made in practice. Exempt Trades This Policy does not apply to: Acquisitions and disposals by gift or inheritance; Acquisitions through an issue of new securities, such as an issue of new shares on the exercise of options, under a rights issue, or a dividend reinvestment plan; Acquisitions of securities through a managed saving plan, such as the Regular Savings Plan operated by Smartshares Limited. If you do not understand any part of this Policy, July of 9

3 or how it applies to you, you should raise the matter with Corporate Counsel before engaging in a trade involving any security covered by this Policy. 2. Trading Procedures Requests to Trade Prior to carrying out a Restricted Trade a written request to trade must be submitted to Corporate Counsel using the form attached as Schedule A to this Policy. At the time that you submit the form you must: Confirm that you do not hold material information; and Confirm that you know of no reason to prohibit the Restricted Trade. You should not carry out a Restricted Trade before receiving approval from Corporate Counsel. Process for Review of Requests to Trade Each request to trade will be reviewed in accordance with Schedule B to this Policy, and a written response will be provided to the employee, senior manager or director in each case. Consent to Trade Where consent to a trade is given, it is only valid for a period of 10 trading days after notification. The order for the trade should be placed after the close of the market. Consent may be withdrawn at any time and shall be deemed to be automatically withdrawn if the person becomes aware of material information prior to trading. Please note that consent does not provide a defence to non-compliance with, or any breach of, insider trading laws. The requirements imposed by this Policy are separate from, and in addition to, the legal prohibitions on insider trading in New Zealand and any other countries where those securities may be quoted. Responsibility for complying with this Policy and applicable laws and regulations rests with the individual. Black-Out Periods NZX has designated black-out periods connected to the release of its financial results to the market. During the black-out periods, senior managers and directors of NZX or any NZX subsidiary are prohibited from trading in any security issued by NZX or any NZX subsidiary (other than investments in funds issued or managed by NZX Group s fund management businesses -Smartshares Limited and SuperLife Limited) without the specific permission of NZX s Board. The applicable black-out periods are as follows: 1 day prior to NZX s half year balance dates or such other date as communicated by the Corporate Counsel, until the first trading day after the half-year results are released to the market; 1 day prior to NZX s year end balance date or such other date as communicated by the Corporate Counsel, until the first trading day after the full-year results are released to the market; July of 9

4 1 day prior to NZX s first and third quarter balance dates or such other date as communicated by the Corporate Counsel, until the first trading day after the quarterly revenues and operating metrics are released to the market; and 30 days prior to release of a product disclosure statement for a general public offer of securities by NZX or its subsidiaries (excluding SmartShares and SuperLife). Requirements after trading All employees, senior managers and directors of NZX or subsidiary of NZX should notify Corporate Counsel promptly after completing a trade in a security issued by NZX or any NZX subsidiary. It is the individual s responsibility to ensure compliance with any disclosure obligations under Subpart 6 of the Financial Markets Conduct Act 2013 (Disclosure of relevant interests in quoted securities by directors and senior managers of listed issuers). The forms to be completed under the legislation are available at: If you have any concerns as to compliance with those obligations, you should discuss this with Corporate Counsel. 3. Important Information Insider trading is prohibited at all times New Zealand law prohibits trading by a person who is an information insider. You are an information insider if you have material information relating to an issuer or a derivative (or its underlying or its issuer) and you know or ought reasonably to know that the information is material and is not generally available to the market. Schedule C provides a description of Material Information. If you are an information insider, it is illegal for you to: Trade securities; Advise or encourage another person to trade or hold the securities; or Advise or encourage a person directly or indirectly to advise or encourage another person to trade or hold the securities. The prohibitions apply regardless of how you learn of the information, and regardless of why you are trading. This offence of insider trading can subject you to criminal liability including large fines and/or imprisonment, and civil liability, which may include being sued by another party or NZX for any loss suffered as a result of illegal trading. Approval of a Restricted Trade does not exempt any individual from insider trading offences. Confidential information All employees, senior managers and directors of NZX or a subsidiary of NZX have a duty of confidentiality to NZX. You must not reveal any confidential information concerning NZX to a third party (unless that third party has signed a confidentiality agreement with NZX and you have been authorised to disclose the confidential information), or to use confidential information in any way which may harm or cause loss to NZX, or use confidential information to gain an July of 9

5 advantage for yourself. You should also ensure that external advisers keep NZX information confidential. Short term trading discouraged Short term trading (the buying or selling of securities within a 6 month period for half yearly reporting Issuers or a 3 month period for quarterly reporting Issuers) can be a key indicator of insider trading, particularly if undertaken on a regular basis or in large amounts. Therefore, to reduce the risk of an allegation of insider trading, we strongly recommend that you do not trade securities of NZX listed issuers on a short-term basis. Restricted securities issued under an employee incentive plan From time to time, NZX may offer eligible employees the opportunity to subscribe for securities issued by NZX as payment of remuneration pursuant to the terms of an employee incentive plan (including a senior manager or employee share scheme). For as long as the securities issued under an NZX employee incentive plan are restricted (i.e. the conditions for vesting of the securities to the employee have not been met), employees of NZX are prohibited from trading in any derivatives or entering into any bespoke structured hedge positions relating to such securities, without prior consent. Requests to trade (or enter any hedging arrangement) should be submitted in the same manner as for a Restricted Trade under this Policy. There will be a presumption against granting consent except in extraordinary circumstances which should be clearly set out in the request to trade If in doubt, don t The rules and procedures contained in this Policy do not replace your legal obligations. The boundary between what is and what is not in breach of the law is not always clear. Sometimes behaviour that you consider to be ethical actually may be insider trading. If in doubt, don t trade. Breaches of Policy Strict compliance with this Policy is a condition of employment. Breaches of this Policy will be subject to disciplinary action, which may include termination of employment. Monitoring of trading NZX will, at its discretion, monitor the trading of employees, senior managers and directors as part of the administration of this Policy. Board Approval The Board of NZX has approved this Policy. The Board may approve updates, amendments to and exemptions to this Policy from time to time, which may be implemented by written notice to you or posting on NZX s wiki page. To the extent of any inconsistency with any previous Policy or rules relating to this subject matter, this Policy prevails over them. July of 9

6 SCHEDULE A Request for Consent to Trade To: Corporate Counsel, NZX Limited ( NZX ) In accordance with the, I request NZX s consent be given to the following proposed trade to be undertaken either by me or persons associated with me, within 10 trading days of approval being given. I acknowledge NZX is not advising or encouraging me to trade or hold any security and does not provide any recommendation in this respect. Name: Position: Name of registered holder trading (if different): Description of securities: Number of securities to be traded (if known): Type of proposed trade: Purchase/sale/other (specify) To be traded: Likely date of trade (on or about): On NZX/off-market trade/other (specify) I declare that I do not hold information which: is not generally available to the market; and would have a material effect on the price of the securities listed above if it were generally available to the market. I know of no reason to prohibit me from trading in the securities listed above and certify that the details given above are complete, true and correct. Signature Date Please submit this form via to: July of 9

7 SCHEDULE B REQUEST TO TRADE REVIEW PROCESS As described below, the appropriate process to review requests to trade will depend on whether the security to be traded has been issued by NZX and its subsidiaries or by another entity. For the purposes of this Schedule: NZX Security means any security issued by NZX or an NZX subsidiary. Non-NZX Security means: Any security offered by an entity (other than NZX or an NZX subsidiary) that is listed on a market operated by NZX; or Any security quoted for trading on a market operated by NZX or its subsidiaries Requests to trade NZX Security Employees and Senior Managers: Upon receipt of a request from an employee (excluding the CEO and Head of Market Supervision) to trade an NZX Security: Corporate Counsel will advise whether there is any matter that would prevent trading by that staff member (e.g. matter before Special Division); and The employee s manager will advise whether there is any matter which would prevent trading by that staff member; and Upon receipt of advice from Corporate Counsel in respect of (i) and (ii) above, one of the CEO or Head of Market Supervision may provide permission for the trade. Directors: A request from a Director (excluding the CEO and Chairman of the Board of Directors of NZX ( Chairman )) to trade an NZX Security will be reviewed by the Chairman, CEO and Head of Market Supervision upon receiving a recommendation from Corporate Counsel. CEO: A request from the CEO to trade an NZX Security will be reviewed by the Chairman and the Head of Market Supervision upon receiving a recommendation from Corporate Counsel. Chairman: A request from the Chairman to trade an NZX Security will be reviewed by the CEO, Chair of the Audit and Risk Committee, and Head of Market Supervision upon receiving a recommendation from Corporate Counsel. Head of Market Supervision: A request from the Head of Market Supervision to trade an NZX Security will be reviewed by the CEO and the Chairman. Requests to trade Non-NZX Security Note that this section only applies to employees and senior managers of NZX and its subsidiaries. Employees and Senior Managers: Upon receipt of a request from an employee (excluding the CEO and Head of Market Supervision) to trade a Non-NZX Security: NZX Market Supervision is requested by the Corporate Counsel to advise whether there is any matter being dealt with which would prevent trading by that employee; The employee s manager is requested to advise whether there is any matter that would prevent trading by that employee; and July of 9

8 Upon receipt of advice in respect of (i) and (ii) above, Corporate Counsel or its delegate may provide permission for the trade. CEO: A request from the CEO to trade a Non-NZX Security will be reviewed by the Head of Market Supervision upon receiving a recommendation from Corporate Counsel. Head of Market Supervision: A request from the Head of Market Supervision to trade a Non- NZX Security will be reviewed by the CEO and Corporate Counsel. Considerations Each request to trade will be considered on a case-by-case basis and, without limiting their discretion, the parties may take into consideration: The information available to NZX as a result of its position as operator of the securities and energy markets in New Zealand; The information available to NZX as a result of any commercial relationship with an entity; The position of the employee, senior manager or director and that person s access to information about the issuer or derivative; and Any other exceptional circumstances. July of 9

9 SCHEDULE C MATERIAL INFORMATION Material information is information that a reasonable person would expect, if it were generally available to the market, would have a material effect on the price of quoted securities of a specific company. It is not information that would have a material impact on securities generally or listed issuers generally. Information is generally available to the market if it has been released as an NZX announcement, or investors that commonly invest in the securities can readily obtain the information. It does not matter how you come to know the material information (including whether you learn it in the course of carrying out your responsibilities, or in passing in the corridor, or in a lift, or at a social function). Information includes rumours, matters of supposition, intentions of a person (including NZX), and information, which is insufficiently definite to warrant disclosure to the public. What are some examples of material information? The following are examples of information about a company that will generally be material if the information is not currently available to the market: The financial performance of a company; A possible acquisition or sale of any assets or part of the business; Entry into or the likely entry into or termination or likely termination of material contracts or other business arrangements which are not publicly known; A possible change in a company s capital structure; The following are additional examples of information about a company that could be material, depending on the magnitude or context: A possible change in the strategic direction; The introduction of an important new product or service; A legal claim by or against the company; Senior management changes; and A change in the historical pattern of dividends. July of 9

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