INSIDER TRADING POLICY ZIGGO N.V. EFFECTIVE AS OF Declaration of agreement with the Insider Trading Policy

Size: px
Start display at page:

Download "INSIDER TRADING POLICY ZIGGO N.V. EFFECTIVE AS OF 18.07.2013. Declaration of agreement with the Insider Trading Policy"

Transcription

1 INSIDER TRADING POLICY ZIGGO N.V. EFFECTIVE AS OF CONTENTS (1) Definitions (2) General rules applicable to all Employees (3) Additional rules for Insiders (4) Compliance Officer APPENDICES (I) (II) (III) Declaration of agreement with the Insider Trading Policy Internal reporting form Statutory prohibitions and sanctions AMSDAM v

2 1. DEFINITIONS 'Affiliated Company' means every Dutch limited liability company (naamloze vennootschap naar Nederlands recht) the (depositary receipts for) shares of which have been admitted to trading on a regulated market as meant in Article 1, under 13, of the Council Directive 93/22/EEC of 10 May 1993 on investment services in the securities field, (a) (b) belonging to the same group as Ziggo or in which Ziggo has a participating interest as referred to in article 2:24c of the Dutch Civil Code (Burgerlijk Wetboek) if the turnover of that limited liability company, as most recently determined, constitutes at least 10% of the consolidated turnover of Ziggo, or which provides directly or indirectly more than 25% of the capital of Ziggo. 'Affiliated Financial Instruments' are (depository receipts for) shares in the capital of an Affiliated Company and rights pursuant to an agreement to acquire (depository receipts for) shares in the capital of an Affiliated Company. 'Affiliated Persons' are (a) (b) (c) (d) spouses, registered partners or life partners of, or other persons cohabitating with a member of the management board, member of the supervisory board or Executive as if they were married or registered as partners; children of a member of the management board, member of the supervisory board or Executive who fall under his authority or who are under legal restraint and for whom such person was appointed as a guardian; other relatives by blood or otherwise of a member of the management board, member of the supervisory board or Executive who have shared a joint household with him or her for at least one year; or a legal entity, a trust as referred to in Section 1 under c of the Act on the Supervision of Trust Offices (Wet toezicht trustkantoren) or a partnership, the executive responsibility of which is vested in a member of the management board, member of the supervisory board or Executive or in a person referred to under a, b or c above, which is controlled by a member of the management board, member of the supervisory board or Executive, which has been created for his benefit, or the economic interests of which are essentially equivalent to his, but excluding, for the avoidance of doubt, any legal entity, fund, trust or partnership that a member of the supervisory board is affiliated with or on which a member of the supervisory board has a position as an executive or non-executive director, but the exclusive responsibility is not vested in such member, which is not controlled by such member or which has not been created for such member's benefit (2)

3 'AFM' means Authority for the Financial Markets (Autoriteit Financiële Markten). 'Open Period' is a period of four weeks starting the day after the publication of the annual, half-yearly or quarterly results of Ziggo. 'Employees' are persons employed by, or in any other relationship of authority to, Ziggo NV or a subsidiary or group company of Ziggo NV, including members of the management board, members of the supervisory board and Executives. 'Executives' are Employees, not being members of the management board of Ziggo NV or members of the supervisory board of Ziggo NV, who have an executive position within Ziggo and on that basis have the power to take decisions which have an effect on the future development and prospects of Ziggo NV and who may regularly have access to Inside Information. 'FMSA' means the Dutch Financial Markets Supervision Act (Wet op het financieel toezicht) and any ancillary rules, decrees and regulations thereto, as amended from time to time. 'Inside Information' is knowledge of information of a precise nature which has not been made public, relating, directly or indirectly, to Ziggo NV or to the trade in Ziggo Financial Instruments and which, if it were made public, would have a significant influence on the price of (either listed or unlisted) Ziggo Financial Instruments. Examples include non-public information regarding (semi-) annual figures or quarterly figures, planned mergers or take-overs, planned share issues, special orders, and new products or services. 'Insider List' means a list of persons employed by Ziggo who, either regularly or occasionally, may have access to Inside Information. 'Insider Trading Policy' means this insider trading policy. 'Insiders' are members of the management board, members of the supervisory board, Executives, Affiliated Persons and individuals within the Ziggo group designated by the compliance officer as Insider. 'trading' means any direct or indirect transaction relating to Ziggo Financial Instruments, including exchanging or donating financial instruments, buying or writing options, exercising options, conversion of convertible bonds, effecting a transaction executed by a third party, and trying to trade in Ziggo Financial Instruments. 'Ziggo' means Ziggo N.V., a public company with limited liability (naamloze vennootschap met beperkte aansprakelijkheid) incorporated under Dutch law, with its statutory seat in Utrecht, the Netherlands, and with registered address Atoomweg 100, 3542 AB Utrecht, the Netherlands, registered with the Dutch Commercial Register (Handelsregister) under number (3)

4 'Ziggo Financial Instruments' means the ordinary shares in the capital of Ziggo that are traded on Euronext and any other future financial instruments that relate to Ziggo or of which the price is determined (wholly or partly) by Ziggo Financial Instruments. 2. GENERAL RULES APPLICABLE TO ALL EMPLOYEES 2.1. General For the purpose of the provisions set out in this chapter, Ziggo Financial Instruments shall also mean the bonds issued by Ziggo that are traded on the Luxembourg Stock Exchange Prohibitions for all Employees (1) All Employees who have Inside Information are prohibited from trading in Ziggo Financial Instruments. (2) All Employees who have Inside Information are prohibited from recommending or inducing third parties to trade in Ziggo Financial Instruments. (3) Trading in Ziggo Financial Instruments is prohibited if this might reasonably create the appearance that the person(s) involved had Inside Information or used such information. (4) All Employees who posses Inside Information are prohibited from disclosing Inside Information concerning Ziggo NV or the trading in Ziggo Financial Instruments to a third party, unless (i) this occurs within the scope of the normal fulfilment of one s work or duties, and (ii) the recipient of the Inside Information is subject to confidentiality undertakings in this respect Other rules for all Employees (1) Employees should take due care when handling Inside Information. Discussing it and other business information in a domestic setting should be avoided. (2) For the purpose of an inquiry as referred to in paragraph 4.1 under (11) Employees are obliged to render as much assistance as possible Exceptions The prohibition described in article 2.2 under (1) shall not apply to: (1) an Employee who trades in Ziggo Financial Instruments in order to fulfil a due obligation which already existed when the Employee acquired the Inside Information; (4)

5 (2) the acceptance, within the scope of a stock option plan, of options, if a consistent course of action is followed with regard to the conditions and periodicity of the plan; (3) the exercise of options within the scope of a stock option plan, on the date of expiry of the option or within a period of five business days prior thereto; furthermore, the sale within said period of the Financial Instruments acquired by exercising the options, provided that the person concerned has, at least four months prior to expiry, notified the Compliance Officer in writing of his intention to sell (said person being in such case under the obligation to sell) or has granted Ziggo NV an irrevocable power of attorney regarding the sale; (4) the receipt of Ziggo Financial Instruments as payment of dividend, except when such receipt is optional; (5) the selling of Ziggo Financial Instruments that have been accepted within the scope of a stock option plan, following a consistent course of action with regard to the conditions and periodicity of the plan, as long as (i) these Ziggo Financial Instruments are sold immediately after the selling becomes possible under the conditions of the plan, and (ii) the proceeds of the selling are immediately used for the payment of a tax debt that was caused by the acceptance of the Ziggo Financial Instruments within the scope of the plan; and (6) any circumstances that fall under the scope of any other exemptions or exceptions available to an Employee under the FMSA from time to time. 3. ADDITIONAL RULES FOR INSIDERS 3.1. Additional prohibitions for Insiders (1) Insiders are prohibited from trading in Ziggo Financial Instruments outside an Open Period, irrespective of whether they have Inside Information, unless they have received written dispensation from the compliance officer and do not have Inside Information. (2) During an Open Period, Insiders are prohibited from trading in Ziggo Financial Instruments if the compliance officer has prohibited them from doing so in accordance with the terms of this Insider Trading Policy. (3) The compliance officer can from time to time determine that Insiders are prohibited from trading in a third party's financial instruments listed on a stock exchange if and to the extent that this is necessary in order to avoid the appearance of market abuse. (4) Insiders are prohibited from trading in options on Ziggo Financial Instruments or in other financial instruments, the value of which is wholly or partly determined by the value of Ziggo Financial Instruments, with the (5)

6 3.2. Exceptions exception of options that have been granted by Ziggo NV following a stock option plan, unless they have received written dispensation from the compliance officer and do not have Inside Information. The prohibitions mentioned in article 3.1 do not apply to transactions as referred to in article Reporting obligations for Insiders Members of the management board and supervisory board must notify the AFM: (1) within two weeks of their designation or appointment of the number of Ziggo Financial Instruments and Affiliated Financial Instruments at their disposal, and of the number of votes they can cast on the issued capital of Ziggo and the issued capital of Affiliated Companies; (2) immediately after a company has become an Affiliated Company of the number of Affiliated Financial Instruments at their disposal, and of the number of votes they can cast on the issued capital of the Affiliated Company; (3) immediately of any change in the number of Ziggo Financial Instruments and Affiliated Financial Instruments at their disposal, and of any change in the number of votes they can cast on the issued capital of Ziggo NV and Affiliated Companies. Members of the management board, supervisory board, Executives and Affiliated Persons must notify the AFM: (4) no later than on the fifth business day after the transaction of any transaction in Ziggo Financial Instruments, conducted for his or her account. 1 Reporting obligations for all Insiders: (5) The compliance officer must be notified of a transaction in Ziggo Financial Instruments that an Insider intends entering into at least 3 business days in advance. (6) Insiders must immediately report transactions in Ziggo Financial Instruments conducted by or for them to the compliance officer by using the form which is attached to this Insider Trading Policy as Appendix II. 1 For a member of the management board or the supervisory board, the obligation to report transactions in Ziggo Financial Instruments conducted by or for him to the AFM shall be met if pursuant to article 3.3 under (3) above the AFM has been timely notified of the change in the number of Ziggo Financial Instruments caused by this transaction (6)

7 (7) Insiders may request the compliance officer to fulfil the notification obligations to the AFM on their behalf. (8) Insiders may request their independent portfolio manager to fulfil the notification obligations to the AFM on their behalf. They must inform the compliance officer accordingly. (9) Insiders will at all times remain ultimately responsible for the compliance with their notification duties within the relevant timeframe Other rules for Insiders (1) The above prohibitions remain applicable to Insiders during the six months after termination of their function or removal of the Insider List. (2) After having familiarised themselves with the content of this Insider Trading Policy, Insiders must send a signed copy of the declaration of agreement with the Insider Trading Policy, as attached as Appendix I, to the compliance officer. 4. COMPLIANCE OFFICER Compliance officer at Ziggo NV is currently Jan Pieter Witsen Elias, T: +31 (0) or +31 (0) The compliance officer's tasks (1) to announce, in due time, at least prior to the beginning of each calendar year, the Open Periods, as well as any changes or additions in that regard; (2) to keep Insider Lists and inform those persons added to an Insider List in writing of their placement on the list and the prohibitions relating to the possession of inside information and the sanctions imposed upon violation of those provisions (see Appendix III); (3) to designate Employees as Insiders on a temporary basis; (4) to prohibit Insiders, if and when necessary, from executing transactions in Ziggo Financial Instruments inside an Open Period; (5) to prohibit Insiders from trading in a third party's financial instruments if and to the extent that this is necessary in order to avoid the appearance of market abuse; (6) to grant dispensation from the prohibitions as referred to in paragraph 2.2; (7) to notify the members of the management board and the supervisory board in writing of the limited liability companies that are regarded as Affiliated Companies for the purpose of this Insider Trading Policy; (7)

8 (8) to notify the AFM of transactions in Ziggo Financial Instruments by Insiders as referred to in paragraph 3.3, if and insofar as required by law; (9) to provide, when requested, Employees with advice and information on the content and interpretation of the various regulations, without thereby releasing Employees from their statutory responsibilities and duties; (10) to register notifications, requests, decisions and other relevant documents with regard to this Insider Trading Policy; (11) to hold an inquiry, or effect that an inquiry be held, with regard to the correct compliance of this Insider Trading Policy, and report in writing on the outcome of the inquiry to the chairman of the supervisory board, but only after having given the person concerned the opportunity to respond to (the outcome of) the inquiry; and (12) to supervise the correct compliance with this Insider Trading Policy. Upon discovery of an act or omission which violates any of the regulations of this Insider Trading Policy, appropriate measures will be taken against the person concerned (8)

9 APPENDIX I [Declaration of agreement with the Insider Trading Policy] (9)

10 APPENDIX II Internal Reporting Form (1) Name and address of the person with the obligation to report:.... (2) Type of financial instrument (for example, share, debt instrument, option, warrant):.. (3) Type of transaction (purchase/sale):.. (4) Company that issued the financial instrument (if other than Ziggo NV):.. (5) Reason for reporting the transaction:.. (6) To be filled in insofar as applicable: - Nominal value of the financial instrument (in ): - Option series (call option / put option): - Exercise price (in ): - Date of expiry : (7) Date of the transaction: (8) Total number of Ziggo NV Financial Instruments or Affiliated Financial Instruments held before the transaction: (9) Number of financial instruments purchased or sold: (10)

11 (10) Total number of Ziggo NV or Affiliated Financial Instruments held after the transaction: (11) Price of the financial instruments (in ): Thus drawn up truthfully: Place: Date: Name: Signature: (11)

12 APPENDIX III Prohibitions and sanctions mentioned in the Act on Financial Supervision (Wet op het financieel toezicht) The prohibitions listed in Section of the Act on Financial Supervision (Wet op het financieel toezicht), and the sanctions that may be imposed in case of violation of these prohibitions, are as follows: Article 5:56 paragraph 1: "Het is een ieder die behoort tot een in het tweede lid genoemde categorie personen verboden om gebruik te maken van voorwetenschap door een transactie te verrichten of te bewerkstelligen: a. in of vanuit Nederland of een staat die geen lidstaat is in financiële instrumenten die zijn toegelaten tot de handel op een gereglementeerde markt in Nederland of waarvoor toelating tot die handel is aangevraagd; b. in of vanuit Nederland in financiële instrumenten die zijn toegelaten tot de handel op een gereglementeerde markt in een andere lid-staat of die zijn toegelaten tot de handel op een markt in financiële instrumenten die is gevestigd en van overheidswege toegelaten in een staat die geen lidstaat is, of in financiële instrumenten waarvoor toelating tot die handel is aangevraagd; of c. in of vanuit Nederland of een staat die geen lidstaat is financiele instrumenten, niet zijnde financiële instrumenten als bedoeld in onderdeel a of b, waarvan de waarde mede wordt bepaald door in onderdeel a of b bedoelde financiële instrumenten". which can be translated as: "It shall be prohibited for any person who belongs to a category of persons mentioned in paragraph two to make use of inside information by executing or effecting a transaction: a. in or from within the Netherlands or a state which is not a member state in financial instruments that have been admitted to trading on a regulated market in the Netherlands or for which admission to such trading has been requested; b. in or from within the Netherlands in financial instruments that have been admitted to trading on a regulated market in another member state or that have been admitted to trading on a market for financial instruments established in and officially admitted in a state which is not a member state, or in financial instruments for which a request for admission to such trading has been made; or c. in or from within the Netherlands or a state which is not a member state in financial instruments not being financial instruments as meant under a or b, the (12)

13 Sanctions: value of which is partly determined by the financial instruments meant under a or b". In case of violation of Article 5:56 paragraph 1 of the Act on Financial Supervision, the Authority for the Financial Markets can decide to impose an administrative fine with a base amount of The maximum administrative fine is Following notification to the offender that such a decision has been taken, the Authority for the Financial Markets will, in principle, publish its decision. Once the imposition of the fine has become final (possibly after objection and appeal), the Authority for the Financial Markets will publish, once again, the decision to impose the fine. In case of a criminal investigation and conviction, violation of Article 5:56 paragraph 1 of the Act on Financial Supervision (designated, by Article 1 under 3 o and Article 2, paragraph 3 of the Economic Offences Act, in conjunction with Article 5:54 of the Act on Financial Supervision, as an economic offence) can lead to the imposition of (Article 6 paragraph one under 2 o of the Economic Offences Act) a prison sentence of two years and/or a fine to a maximum of 19,000 for natural persons (or a maximum of 76,000 in case the proceeds of the crime exceed 4,750), and, for legal persons, a fine to a maximum of 760,000. Article 5:56 paragraph 3: "Het is een ieder die niet behoort tot een in het tweede lid genoemde categorie en die weet of redelijkerwijs moet vermoeden dat hij over voorwetenschap beschikt, verboden om gebruik te maken van die voorwetenschap door: a. in of vanuit Nederland of een staat die geen lidstaat is een transactie te verrichten of te bewerkstelligen in financiële instrumenten als bedoeld in het eerste lid, onderdeel a; b. in of vanuit Nederland een transactie te verrichten of te bewerkstelligen in financiële instrumenten als bedoeld in het eerste lid, onderdeel b; of c. in of vanuit Nederland of een staat die geen lidstaat is een transactie te verrichten of te bewerkstelligen in financiële instrumenten als bedoeld in het eerste lid, onderdeel c". which can be translated as: "It shall be prohibited for any person who does not belong to a category mentioned in paragraph two and who knows or should reasonably suspect that he has inside information, to make use of this inside information by a. executing or effecting a transaction, in or from within the Netherlands or a state which is not a member state, in financial instruments as meant in the first paragraph, subsection a; (13)

14 Sanctions: b. executing or effecting a transaction, in or from within the Netherlands, in financial instruments as meant in the first paragraph, subsection b; or c. executing or effecting, in or from within the Netherlands or a state which is not a member state, in financial instruments as meant in the first paragraph, subsection c". In case of violation of Article 5:56 paragraph 3 of the Act on Financial Supervision, the Authority for the Financial Markets can impose an administrative fine with a base amount of The maximum administrative fine is Following notification to the offender that such a decision has been taken, the Authority for the Financial Markets will, in principle, publish its decision. Once the imposition of the fine has become final (possibly after objection and appeal), the Authority for the Financial Markets will publish, once again, the decision to impose the fine. In case of a criminal investigation and conviction, violation of Article 5:56 paragraph 3 of the Act on Financial Supervision (designated, by Article 1 under 3 o and Article 2, paragraph 3 of the Economic Offences Act, in conjunction with Article 5:54 of the Act on Financial Supervision, as an economic offence) can lead to the imposition of (Article 6 paragraph one under 2 o of the Economic Offences Act) a prison sentence of two years and/or a fine to a maximum of 19,000 for natural persons (or a maximum of 76,000 in case the proceeds of the crime exceed 4,750), and, for legal persons, a fine to a maximum of 760,000. Article 5:56 paragraph 7: "Het is verboden om gebruik te maken van voorwetenschap door te trachten een transactie te verrichten of te bewerkstelligen als bedoeld in het eerste lid". which can be translated as: Sanctions: "It shall be prohibited to make use of inside information by trying to execute or effect a transaction as meant in paragraph one". In case of violation of Article 5:56 paragraph 7 of the Act on Financial Supervision, the Authority for the Financial Markets can impose an administrative fine with a base amount of The maximum administrative fine is Following notification to the offender that such a decision has been taken, the Authority for the Financial Markets will, in principle, publish its decision. Once the imposition of the fine has become final (possibly after objection and appeal), the Authority for the Financial Markets will publish, once again, the decision to impose the fine (14)

15 In case of a criminal investigation and conviction, violation of Article 5:56 paragraph 7 of the Act on Financial Supervision (designated, by Article 1 under 3 o and Article 2, paragraph 3 of the Economic Offences Act, in conjunction with Article 5:54 of the Act on Financial Supervision, as an economic offence) can lead to the imposition of (Article 6 paragraph 1 under 2 o of the Economic Offences Act) a prison sentence of two years and/or a fine to a maximum of 19,000 for natural persons (or a maximum of 76,000 in case the proceeds of the crime exceed 4,750), and, for legal persons, a fine to a maximum of 760,000. Article 5:57 paragraph 1: "Het is een ieder die behoort tot een in artikel 5:56, tweede lid, onderdeel a, b of d bedoelde categorie, alsmede een ieder die beschikt over voorwetenschap en behoort tot de in artikel 5:56, tweede lid, onderdeel c, bedoelde categorie verboden om in of vanuit een in artikel 5:56, eerste lid, onderdeel a, b, of c bedoelde staat, voor zover het financiële instrumenten betreft als bedoeld in het betreffende onderdeel: a. de informatie waarop zijn voorwetenschap betrekking heeft aan een derde mee te delen, anders dan in de normale uitoefening van zijn werk, beroep of functie; of b. een derde aan te bevelen of ertoe aan te zetten transacties te verrichten of te bewerkstelligen in die financiële instrumenten". which can be translated as: Sanctions: "In or from within a state as meant in Article 5:56, second paragraph, subsection a, b or c, and in respect of financial instruments as meant in the relevant subparagraph, it shall be prohibited for any person who belongs to a category as meant in Article 5:56, second paragraph, subsection a, b or d, as well as for any person who has inside information and belongs to the category meant in Article 5:56, second paragraph, subsection c, to a. disclose the information forming the object of his inside information to a third party, outside the normal practice of his work, profession or function; or b. recommend or induce a third party to execute or effect transactions in these financial instruments". In case of violation of Article 5:57 paragraph 1 of the Act on Financial Supervision, the Authority for the Financial Markets can impose an administrative fine with a base amount of The maximum administrative fine is Following notification to the offender that such a decision has been taken, the Authority for the Financial Markets will, in principle, publish its decision. Once the imposition of the fine has become final (possibly after objection and appeal), the Authority for the Financial Markets will publish, once again, the decision to impose the fine (15)

16 In case of a criminal investigation and conviction, violation of Article 5:57 paragraph 1 of the Act on Financial Supervision (designated, by Article 1 under 3 o and Article 2, paragraph 3 of the Economic Offences Act, in conjunction with Article 5:54 of the Act on Financial Supervision, as an economic offence) can lead to the imposition of (Article 6 paragraph one under 2 o of the Economic Offences Act) a prison sentence of two years and/or a fine to a maximum of 19,000 for natural persons (or a maximum of 76,000 in case the proceeds of the crime exceed 4,750), and, for legal persons, a fine to a maximum of 760,000. Article 5:57 paragraph 2: "Het eerste lid is van overeenkomstige toepassing op ieder ander die weet of redelijkerwijs moet vermoeden dat hij over voorwetenschap beschikt". which can be translated as: Sanctions: "The first paragraph is applicable by analogy to any other person who knows or should reasonably suspect that he has inside information". In case of violation of Article 5:57 paragraph 2, the Authority for the Financial Markets can impose an administrative fine with a base amount of The maximum administrative fine is Following notification to the offender that such a decision has been taken, the Authority for the Financial Markets will, in principle, publish its decision. Once the imposition of fine has become final (possibly after objection and appeal), the Authority for the Financial Markets will publish, once again, the decision to impose the fine. In case of a criminal investigation and conviction, violation of Article 5:57, paragraph 2 of the Act on Financial Supervision (designated, by Article 1 under 3 o and Article 2, paragraph 3 of the Economic Offences Act, in conjunction with Article 5:54 of the Act on Financial Supervision, as an economic offence) can lead to the imposition of (Article 6 paragraph 1 under 2 o of the Economic Offences Act) a prison sentence of two years and/or a fine to a maximum of 19,000 for natural persons (or a maximum of 76,000 in case the proceeds of the crime exceed 4,750), and, for legal persons, a fine to a maximum of 760,000. Article 5:58 paragraph 1: "Het is verboden om in of vanuit een in artikel 5:56, eerste lid, onderdeel a of b, bedoelde staat, telkens voor zover het financiële instrumentenbetreft als bedoeld in het desbetreffende onderdeel: a. een transactie of handelsorder in financiële instrumentente verrichten of te bewerkstelligen waarvan een onjuist of misleidend signaal uitgaat of te duchten is met betrekking tot het aanbod van, de vraag naar of de koers van die financiële instrumenten, tenzij degene die de transactie of handelsorder heeft verricht of bewerkstelligd, aantoont dat zijn beweegreden om de transactie of handelsorder te (16)

17 verrichten of te bewerkstelligen gerechtvaardigd is en dat de transactie of handelsorder in overeenstremming is met de gebruikelijke marktpraktijk op de desbetreffende gereglementeerde markt; b. een transactie of handelsorder in financiële instrumentente verrichten of te bewerkstelligen teneinde de koers van die financiële instrumentenop een kunstmatig niveau te houden, tenzij degene die de transactie of handelsorder heeft verricht of bewerkstelligd, aantoont dat zijn beweegreden om de transactie of handelsorder te verrichten of te bewerkstelligen gerechtvaardigd is en dat de transactie of handelsorder in overeenstremming is met de gebruikelijke marktpraktijk op de desbetreffende gereglementeerde markt; c. een transactie of handelsorder in financiële instrumenten te verrichten of te bewerkstelligen waarbij gebruik wordt gemaakt van bedrog of misleiding; of d. informatie te verspreiden waarvan een onjuist of misleidend signaal uitgaat of te duchten is met betrekking tot het aanbod van, de vraag naar of de koers van financiële instrumenten, terwijl de verspreider van die informatie weet of redelijkerwijs moet vermoeden dat die informatie onjuist of misleidend is". which can be translated as: "In or from within a state as meant in Article 5:56, first paragraph, subsection a or b, it shall be prohibited, insofar as it concerns financial instruments as meant in the relevant subparagraph: a. to execute or effect a transaction or order to trade in financial instruments that sends or can be feared to send an incorrect or misleading signal in respect of the supply of, the demand for or the price of those financial instruments, unless the person who has executed or effected the transaction demonstrates that his reason for executing or effecting the transaction is justified and that the transaction or order to trade in is accordance with the accepted market practice in the relevant regulated market; b. to execute or effect a transaction or order to trade in financial instruments with the intention to keep the price of those financial instruments at an artificial level, unless the person who has executed or effected the transaction demonstrates that his reason for executing or effecting the transaction is justified and that the transaction or order to trade is in accordance with the accepted market practice in the relevant regulated market; c. to execute or effect a transaction or order to trade in financial instruments using fraud or deception; or d. to divulge information that sends or can be feared to send an incorrect or misleading signal in respect of the supply of, the demand for or the price of those financial instruments, while knowing or having reason to suspect that that information is incorrect or misleading" (17)

18 Sanctions: In case of violation of Article 5:58, paragraph 1, of the Act on Financial Supervision, the Authority for the Financial Markets can impose a penalty order (last onder dwangsom) and/or an administrative fine with a base amount of The maximum administrative fine is In case the periodic penalty payment connected to the penalty order is effectively forfeited, the Authority for the Financial Markets will, in principle, publish its decision to impose the penalty order. Following notification to the offender that a decision to impose an administrative fine has been taken, the Authority for the Financial Markets will, in principle, publish its decision. Once the imposition of the fine has become final (possibly after objection and appeal), the Authority for the Financial Markets will publish, once again, the decision to impose the fine. In case of a criminal investigation and conviction, violation of Article 5:58, paragraph 1 of the Act on Financial Supervision (designated, by Article 1 under 3 o and Article 2, paragraph 3 of the Economic Offences Act, in conjunction with Article 5:54 of the Act on Financial Supervision, as an economic offence) can lead to the imposition of (Article 6 paragraph 1 under 2 o of the Economic Offences Act) a prison sentence of two years and/or a fine to a maximum of 19,000 for natural persons (or a maximum of 76,000 in case the proceeds of the crime exceed 4,750), and, for legal persons, a fine to a maximum of 760, (18)

Sequa Petroleum N.V. Group Insider Trading Policy

Sequa Petroleum N.V. Group Insider Trading Policy Sequa Petroleum N.V. Group Insider Trading Policy 1. Definitions 1.1 The following terms apply: AFM Management Board Company means the Dutch Authority for the Financial Markets (Autoriteit Financiële Markten)

More information

BAM regulations on the holding of and effecting transactions in shares and certain other financial instruments

BAM regulations on the holding of and effecting transactions in shares and certain other financial instruments BAM regulations on the holding of and effecting transactions in shares and certain other financial instruments Contents Page Recitals 3 Chapter I Introduction 3 Article 1 Definitions 3 Article 2 Scope

More information

9 August 2015 ALTICE N.V. SHARE TRADING POLICY

9 August 2015 ALTICE N.V. SHARE TRADING POLICY 9 August 2015 ALTICE N.V. SHARE TRADING POLICY ALTICE SHARE TRADING POLICY Altice N.V. (the Company) is a Dutch public limited liability company whose shares are admitted to trading on Euronext Amsterdam.

More information

RoodMicrotec N.V. (the Company) Warrant plan relating to the granting of warrants. (the Plan)

RoodMicrotec N.V. (the Company) Warrant plan relating to the granting of warrants. (the Plan) RoodMicrotec N.V. (the Company) Warrant plan relating to the granting of warrants (the Plan) certified by. 1. Introduction On 25 September 2013, the management board of the Company (the Management Board)

More information

The Code will be modified from time to time to reflect changes in applicable legislation.

The Code will be modified from time to time to reflect changes in applicable legislation. Corporate Instruction n 6.8 First Publication Date: 15 February 2001 Latest update: 3 May 2011 Section : Legal Subject: Insider Dealing Issued by: General Counsel Content: 1 Introduction 2 ALSTOM s Code

More information

F. van Lanschot Bankiers N.V. (incorporated in the Netherlands with its statutory seat in 's-hertogenbosch)

F. van Lanschot Bankiers N.V. (incorporated in the Netherlands with its statutory seat in 's-hertogenbosch) 20 December 2012 FIFTH SUPPLEMENT TO THE BASE PROSPECTUS IN RESPECT OF THE EURO 5,000,000,000 DEBT ISSUANCE PROGRAMME F. van Lanschot Bankiers N.V. (incorporated in the Netherlands with its statutory seat

More information

Code of Ethics Effective June 1, 2015

Code of Ethics Effective June 1, 2015 Code of Ethics Effective June 1, 2015 APPLICABLE RULES AND REGULATIONS Rule 17j-1 of the Investment Company Act of 1940, as amended Rule 204A-1 of the Investment Advisers Act of 1940, as amended I. POLICY

More information

By Directors, Officers and Employees of Hellaby Holdings Limited and its Subsidiaries ( The Company )

By Directors, Officers and Employees of Hellaby Holdings Limited and its Subsidiaries ( The Company ) Code of Conduct for Securities Trading ( Code ) By Directors, Officers and Employees of Hellaby Holdings Limited and its Subsidiaries ( The Company ) Approved by the Board: 10 May 2013 1. Introduction

More information

www.complianceriskmanagement.intranet

www.complianceriskmanagement.intranet www.complianceriskmanagement.intranet ING Groep N.V., 2010 This document may not be distributed outside ING in any way without prior written consent of the ING Corporate Compliance Risk Management department.

More information

SHARE TRADING POLICY

SHARE TRADING POLICY SHARE TRADING POLICY 1 PURPOSE 1.1 SCOPE This policy summarises the law relating to insider trading and sets out the Company s trading policy on buying and selling securities of the Company including shares,

More information

CODE OF ETHICS FOR POINT CAPITAL, INC. STATEMENT OF GENERAL FIDUCIARY

CODE OF ETHICS FOR POINT CAPITAL, INC. STATEMENT OF GENERAL FIDUCIARY Attachment B PRINCIPLES SECTION I. CODE OF ETHICS FOR POINT CAPITAL, INC. STATEMENT OF GENERAL FIDUCIARY This Code of Ethics (the "Code") has been adopted by Point Capital, Inc. (the Corporation ) in compliance

More information

Axway Code of Conduct

Axway Code of Conduct Axway Code of Conduct 1. Preamble The purpose of this Code of Conduct is to describe regulations relating to insider trading applicable to Axway Software S.A. and its subsidiaries ( Axway or the Company

More information

INSIDER TRADING POLICY AND GUIDELINES

INSIDER TRADING POLICY AND GUIDELINES INSIDER TRADING POLICY AND GUIDELINES As a public company, Northern Power Systems Corp. ( Northern Power or the Company ) and its officers, directors and employees are subject to the requirements and restrictions

More information

INSIDER TRADING POLICY

INSIDER TRADING POLICY 1.0 POLICY STATEMENT INSIDER TRADING POLICY This Policy provides guidelines to officers, directors and employees of Dominion Diamond Corporation (the Company ) and other insiders of the Company with respect

More information

Internal policy relating to trading in securities and compliance with French laws and regulations applicable to insider trading.

Internal policy relating to trading in securities and compliance with French laws and regulations applicable to insider trading. «In case of a doubt concerning the interpretation of the text please note that the French document will take precedence. Valeo Internal policy relating to trading in securities and compliance with French

More information

Principles of Fund Governance BNP Paribas Investment Partners Funds (Nederland) N.V.

Principles of Fund Governance BNP Paribas Investment Partners Funds (Nederland) N.V. Principles of Fund Governance BNP Paribas Investment Partners Funds (Nederland) N.V. Versie november 2012 Inleiding Het doel van de Principles of Fund Governance (verder Principles ) is het geven van nadere

More information

Code of Ethics. I. Definitions

Code of Ethics. I. Definitions Code of Ethics Old North State Trust, LLC (the Company ) has adopted this Code of Ethics in recognition of the principle that all Supervised Persons (as defined below) of the Company have a fiduciary duty

More information

Westfield Corporation Security Trading Policy Trading Restrictions. Westfield Corporation Limited (ABN 12 166 995 197)

Westfield Corporation Security Trading Policy Trading Restrictions. Westfield Corporation Limited (ABN 12 166 995 197) Westfield Corporation Security Trading Policy Trading Restrictions Westfield Corporation Limited (ABN 12 166 995 197) Westfield America Management Limited (ABN 66 072 780 619) WESTFIELD CORPORATION SECURITY

More information

Share Trading Policy MGT Resources Limited ACN 131 715 645

Share Trading Policy MGT Resources Limited ACN 131 715 645 Share Trading Policy MGT Resources Limited ACN 131 715 645 75418791/v2 Table of Contents 1. Introduction... 1 2. Definitions... 1 3. Scope of transactions... 2 4. Standards... 2 5. Insider trading... 2

More information

PART I GENERAL. Chapter 1. General provisions. Section 1. General scope of application of the Act

PART I GENERAL. Chapter 1. General provisions. Section 1. General scope of application of the Act 1(49) Unofficial translation Amendments up to 258/2013 included 746/2012 Issued in Helsinki on 14 December 2012 Securities Markets Act Pursuant to the decision of Parliament, the following is enacted:

More information

Share trading policy. Mortgage Choice Limited ABN 57 009 161 979 ME_89157250_10 (W2003)

Share trading policy. Mortgage Choice Limited ABN 57 009 161 979 ME_89157250_10 (W2003) Share trading policy Mortgage Choice Limited ABN 57 009 161 979 2 Share trading policy 1. Introduction 1.1 The shares of Mortgage Choice Limited ABN 57 009 161 979 (the Company) are quoted on the Australian

More information

MCBRIDE plc GUIDELINES ON SHARE TRADING APPROVAL AND INSIDER DEALING

MCBRIDE plc GUIDELINES ON SHARE TRADING APPROVAL AND INSIDER DEALING MCBRIDE plc GUIDELINES ON SHARE TRADING APPROVAL AND INSIDER DEALING 1. INTRODUCTION The Company s Shareholders and the Board would encourage all directors and employees to take a personal interest in

More information

PACIFIC EXPLORATION & PRODUCTION CORPORATION INSIDER TRADING POLICY

PACIFIC EXPLORATION & PRODUCTION CORPORATION INSIDER TRADING POLICY PACIFIC EXPLORATION & PRODUCTION CORPORATION INSIDER TRADING POLICY Introduction: Pacific Exploration & Production Corporation (the Corporation ) encourages all employees to become shareholders on a long-term

More information

Share Trading Policy. Ecosave Holdings Limited ACN 160 875 016. Revision 1: 4 July 2013. 94721781/v2

Share Trading Policy. Ecosave Holdings Limited ACN 160 875 016. Revision 1: 4 July 2013. 94721781/v2 Share Trading Policy Ecosave Holdings Limited ACN 160 875 016 Revision 1: 4 July 2013 94721781/v2 Table of Contents 1. Introduction...1 2. Definitions...1 3. Scope of transactions...2 4. Standards...2

More information

For the purposes of this policy Ordinary Shares and ADS are referred to as shares or securities.

For the purposes of this policy Ordinary Shares and ADS are referred to as shares or securities. Pharmaxis Ltd 1. Introduction The ordinary Shares of Pharmaxis Ltd are listed on the Australian Securities Exchange (ASX) and its American Depositary Shares (ADS) are able to be traded in the US through

More information

INSIDER TRADING AND BLACKOUT POLICY

INSIDER TRADING AND BLACKOUT POLICY INSIDER TRADING AND BLACKOUT POLICY Amended and Restated by the Board of Directors on December 22, 2011 Page 1 of 11 TABLE OF CONTENTS 1. EXECUTIVE SUMMARY... 3 2. INTRODUCTION... 4 3. MATERIAL INFORMATION...

More information

G3 Group Limited. Financial Products Trading Policy and Guidelines. Date adopted: 1 April 2015 Version: 1. 1 P a g e

G3 Group Limited. Financial Products Trading Policy and Guidelines. Date adopted: 1 April 2015 Version: 1. 1 P a g e G3 Group Limited Financial Products Trading Policy and Guidelines Date adopted: 1 April 2015 Version: 1 1 P a g e G3 Group Limited Securities Trading Policy and Guidelines Scope of Policy This G3 Group

More information

Termination of Life on Request and Assisted Suicide (Review Procedures) Act

Termination of Life on Request and Assisted Suicide (Review Procedures) Act Termination of Life on Request and Assisted Suicide (Review Procedures) Act - This Act entered into force on April 1, 2002 - Review procedures of termination of life on request and assisted suicide and

More information

Flight Centre Travel Group Limited attaches its updated share trading policy.

Flight Centre Travel Group Limited attaches its updated share trading policy. 27 August 2015 Flight Centre Travel Group Limited attaches its updated share trading policy. Flight Centre Travel Group Limited ABN 25 003 377 188 Level 2, 545 Queen Street, Brisbane QLD 4000 1. Overview

More information

binding and reader is advised to consult the authoritative Hebrew text in all matters which may affect them. Chapter A: Definitions

binding and reader is advised to consult the authoritative Hebrew text in all matters which may affect them. Chapter A: Definitions The following translation is intended solely for the convenience of the reader. This translation has no legal status and although every effort has been made to ensure its accuracy, the ISA does not assume

More information

Insider Trading and Reporting Policy Revision Date: December 1, 2008

Insider Trading and Reporting Policy Revision Date: December 1, 2008 Subject: Insider Trading and Reporting Policy Revision Date: December 1, 2008 Introduction The integrity of the Canadian capital markets is based on the principle of equal opportunity based on equal access

More information

ACCEPTED MAREKT PRACTICE ON LIQUIDITY AGREEMENTS

ACCEPTED MAREKT PRACTICE ON LIQUIDITY AGREEMENTS ACCEPTED MAREKT PRACTICE ON LIQUIDITY AGREEMENTS Acceptance by the Dutch Ministry of Finance on 4 may 2011 Description of the practice: Transactions and trade orders in shares and participation rights

More information

Consolidated Insurance Mediation Act 1

Consolidated Insurance Mediation Act 1 Consolidated Insurance Mediation Act 1 Act no. 930 of 18 September 2008 This is an Act to consolidate the Insurance Meditation Act, cf. Consolidated Act no. 401 of 25 April 2007, as amended by section

More information

(Informal Translation) Chapter One. General Provisions. 1- The deposit of securities with the Company or with any licensed entity;

(Informal Translation) Chapter One. General Provisions. 1- The deposit of securities with the Company or with any licensed entity; CAPITAL MARKET AUTHORITY (Informal Translation) Central Securities Depository and Registry Law No. 93 of 2000 Chapter One General Provisions Article 1 In this Law, the Company means a company licensed

More information

Rules of Alternative Trading System organised by the BondSpot S.A.

Rules of Alternative Trading System organised by the BondSpot S.A. Rules of Alternative Trading System organised by the BondSpot S.A. text according to legal condition at 1 January 2013 Only the Polish version of these documents is legally binding. This translation is

More information

PHOENIX NEW MEDIA LIMITED STATEMENT OF POLICIES GOVERNING MATERIAL, NON-PUBLIC INFORMATION AND THE PREVENTION OF INSIDER TRADING

PHOENIX NEW MEDIA LIMITED STATEMENT OF POLICIES GOVERNING MATERIAL, NON-PUBLIC INFORMATION AND THE PREVENTION OF INSIDER TRADING PHOENIX NEW MEDIA LIMITED STATEMENT OF POLICIES GOVERNING MATERIAL, NON-PUBLIC INFORMATION AND THE PREVENTION OF INSIDER TRADING Adopted on [ ], 2011 and effective conditional and immediately upon commencement

More information

JOINT CODE OF ETHICS FOR GOLUB CAPITAL BDC, INC. GOLUB CAPITAL INVESTMENT CORPORATION GC ADVISORS LLC

JOINT CODE OF ETHICS FOR GOLUB CAPITAL BDC, INC. GOLUB CAPITAL INVESTMENT CORPORATION GC ADVISORS LLC JOINT CODE OF ETHICS FOR GOLUB CAPITAL BDC, INC. GOLUB CAPITAL INVESTMENT CORPORATION GC ADVISORS LLC Section I Statement of General Fiduciary Principles This Joint Code of Ethics (the Code ) has been

More information

SECURITY TRADING POLICY AMENDED

SECURITY TRADING POLICY AMENDED 19 March 2015 SECURITY TRADING POLICY AMENDED In accordance with ASX listing rule 12.10, Mirvac Group ("Mirvac") [ASX: MGR] advises that it has amended its Security Trading Policy. The amended Policy,

More information

CHAPTER 26.1-02.1 INSURANCE FRAUD

CHAPTER 26.1-02.1 INSURANCE FRAUD CHAPTER 26.1-02.1 INSURANCE FRAUD 26.1-02.1-01. Definitions. As used in this chapter: 1. "Business of insurance" means the writing of insurance or the reinsuring of risks by an insurer, including acts

More information

NEWFIELD EXPLORATION COMPANY INSIDER TRADING POLICY. Restated Effective as of March 1, 2013

NEWFIELD EXPLORATION COMPANY INSIDER TRADING POLICY. Restated Effective as of March 1, 2013 NEWFIELD EXPLORATION COMPANY INSIDER TRADING POLICY Restated Effective as of March 1, 2013 The Board of Directors (the Board ) of Newfield Exploration Company (together with its subsidiaries, Newfield

More information

ALMONTY INDUSTRIES INC. INSIDER TRADING POLICY

ALMONTY INDUSTRIES INC. INSIDER TRADING POLICY 1. Introduction and Purpose ALMONTY INDUSTRIES INC. INSIDER TRADING POLICY Almonty Industries Inc. (the Corporation ) is a Canadian company, it is a reporting issuer in Canada and its securities are listed

More information

M E M O R A N D U M. The Policy provides for blackout periods during which you are prohibited from buying or selling Company securities.

M E M O R A N D U M. The Policy provides for blackout periods during which you are prohibited from buying or selling Company securities. M E M O R A N D U M TO: FROM: All Directors, Officers and Covered Persons of Power Solutions International, Inc. and its Subsidiaries Catherine Andrews General Counsel and Insider Trading Compliance Officer

More information

Insider Trading Policy Approved by the Board of Trustees on September 17, 2015.

Insider Trading Policy Approved by the Board of Trustees on September 17, 2015. Insider Trading Policy Approved by the Board of Trustees on September 17, 2015. AUTOMOTIVE PROPERTIES REAL ESTATE INVESTMENT TRUST A. INTRODUCTION INSIDER TRADING POLICY (the Policy ) 1. This Policy applies

More information

Securities Trading Policy

Securities Trading Policy Securities Trading Policy Owner Policy Authorised by Changes to be approved by Direct questions on Policy to Company Secretariat Board Board Company Secretary Policy to be reviewed no later than Version

More information

CITIZENS, INC. Insider Trading Policy

CITIZENS, INC. Insider Trading Policy CITIZENS, INC. Insider Trading Policy 1. BACKGROUND AND PURPOSE The federal securities laws prohibit any member of the Company s Board of Directors (a Director ) or employee of the Company from purchasing

More information

ON CIRCULATION OF CREDIT INFORMATION AND ACTIVITIES OF CREDIT BUREAUS THE REPUBLIC OF ARMENIA LAW

ON CIRCULATION OF CREDIT INFORMATION AND ACTIVITIES OF CREDIT BUREAUS THE REPUBLIC OF ARMENIA LAW THE REPUBLIC OF ARMENIA LAW ON CIRCULATION OF CREDIT INFORMATION AND ACTIVITIES OF CREDIT BUREAUS Adopted October 22, 2008 Article 1. Subject of Law CHAPTER 1 GENERAL PROVISIONS 1. This law regulates terms

More information

Security Trading Policy

Security Trading Policy Table of Contents 1. Overview...3 2. Insider Trading...3 3. What is Price Sensitive Information...3 4. When is the information Generally Available?...4 5. Consequence of Breach of the Insider Trading Prohibition...4

More information

INSIDER TRADING POLICY (To be read in conjunction with the Disclosure Policy)

INSIDER TRADING POLICY (To be read in conjunction with the Disclosure Policy) A. Statement of Purpose INSIDER TRADING POLICY (To be read in conjunction with the Disclosure Policy) This and Insider Trading Policy (the Policy ) exists to advise all directors, officers, employees and

More information

Articles of Association of Triodos Bank N.V.

Articles of Association of Triodos Bank N.V. TlB Articles of Association of Triodos Bank N.V. CONTINUOUS TEXT of the articles of association of Triodos Bank N.V., with corporate seat in Zeist, after partial amendment to the articles of association,

More information

G R O U P T R A D I N G P O L I C Y

G R O U P T R A D I N G P O L I C Y G R O U P T R A D I N G P O L I C Y 1. INTRODUCTION These guidelines set out the policy on the sale and purchase of securities in the Company. This policy applies to: all Directors of the Company; all

More information

Trading Policy. W:\Policies and Procedures\Corporate\Share Trading Policy - Final.doc

Trading Policy. W:\Policies and Procedures\Corporate\Share Trading Policy - Final.doc Trading Policy Mawson West Ltd Level 1, 1 Walker Avenue West Perth, WA 6005 Telephone: (61 8) 9321 9669 Facsimile: (61 8) 9481 2394 www.mawsonwest.com. 1 Summary of the Trading Policy The Trading Policy

More information

SHARE TRADING POLICY

SHARE TRADING POLICY T +64 4 499 6830 F +64 4 974 5218 E wellington@bathurstresources.co.nz Level 12, 1 Willeston Street Wellington 6011, New Zealand PO Box 5963 Lambton Quay Wellington 6145, New Zealand 30 October 2015 Market

More information

INSIDER TRADING POLICY WENTWORTH RESOURCES LIMITED 21 OCTOBER 2011

INSIDER TRADING POLICY WENTWORTH RESOURCES LIMITED 21 OCTOBER 2011 INSIDER TRADING POLICY WENTWORTH RESOURCES LIMITED 21 OCTOBER 2011 CAL_LAW\ 1322787\3 WENTWORTH RESOURCES LIMITED INSIDER TRADING POLICY 1. DEFINITIONS In this Insider Trading Policy, the following terms

More information

Share Trading Policy. SkyFii Limited ACN 009 264 699 (Company)

Share Trading Policy. SkyFii Limited ACN 009 264 699 (Company) Share Trading Policy SkyFii Limited ACN 009 264 699 (Company) Table of contents 1 Purpose... 1 1.1 Scope... 1 1.2 Who does this policy apply to?... 1 1.3 Further advice... 1 2 Insider trading prohibitions

More information

Authorised Persons Regulations

Authorised Persons Regulations Authorised Persons Regulations Contents Part 1: General Provisions Article 1: Preliminary... Article 2: Definitions... Article 3: Compliance with the Regulations and Rules... Article 4: Waivers... Part

More information

Employee Securities Trading Policy

Employee Securities Trading Policy Employee Securities Trading Policy Regional Express Holdings Limited 1. Application This policy relates to trading in Regional Express Holdings Limited shares and related securities. In this policy: Shares

More information

1. Share Trading Policy

1. Share Trading Policy 1. Share Trading Policy General Trading Policy 1.1. Policy The Board of the Company has established the following policy to apply to trading in the Company s shares on the ASX. This policy applies to those

More information

INSIDER TRADING POLICY

INSIDER TRADING POLICY INSIDER TRADING POLICY a BACKGROUND: This Policy applies to directors, officers and employees at all levels of Alcoa Inc. ( Alcoa ) and of each domestic and foreign subsidiary, partnership, venture or

More information

FORTUNA SILVER MINES INC. (the "Company")

FORTUNA SILVER MINES INC. (the Company) FORTUNA SILVER MINES INC. (the "Company") BLACKOUTS AND SECURITIES TRADING POLICY The Company encourages all employees, officers and directors to become shareholders of the Company on a long-term investment

More information

Guidelines for Insiders

Guidelines for Insiders Guidelines for Insiders TABLE OF CONTENTS 1 General 5 2 Inside information, use of inside information and insiders 6 2.1 Inside information 6 2.2 Prohibited use and disclosure of inside information 7 2.3

More information

provide a brief and high level summary of the law on insider trading; set out the restrictions on dealing in the Company s securities; and

provide a brief and high level summary of the law on insider trading; set out the restrictions on dealing in the Company s securities; and Share Trading Policy 1. Purpose of this policy The purpose of this policy is to: provide a brief and high level summary of the law on insider trading; set out the restrictions on dealing in the Company

More information

GB MINERALS LTD INSIDER TRADING POLICY

GB MINERALS LTD INSIDER TRADING POLICY GB MINERALS LTD INSIDER TRADING POLICY (as approved by the Board of Directors in May 2014) - 2 - Contents 1. POLICY STATEMENT... 3 2. PERSONS AND SECURITIES COVERED BY THIS POLICY... 3 3. MATERIAL NON-PUBLIC

More information

Securities Trading Policy

Securities Trading Policy Securities Trading Policy Issued on 31 December 2010 1. Introduction Purpose The Board encourages Key Management Personnel (including Directors) employees to own securities in Ruralco Holdings Limited

More information

Security-Compliance Guidelines of the Generali Deutschland Group

Security-Compliance Guidelines of the Generali Deutschland Group Security-Compliance Guidelines of the Generali Deutschland Group as at January 2009 Contents Page PART 1: OVERVIEW 3 A. Definition 3 B. Targets 3 C. Scope of application 3 PART 2: COMPLIANCE 3 A. Duties

More information

Rules of Alternative Trading System organised by the BondSpot S.A.

Rules of Alternative Trading System organised by the BondSpot S.A. Rules of Alternative Trading System organised by the BondSpot S.A. The Rules adopted by the Management Board by Resolution No. 103/2009 dated 4 November 2009, as amended by the Management Board: by Resolution

More information

Policy. Practice. Scheduled Trading Blackouts. May 13, 2015

Policy. Practice. Scheduled Trading Blackouts. May 13, 2015 May 13, 2015 Policy To promote compliance with insider trading prohibitions and to avoid any perception that the Company's insiders have engaged in any improper trading, its directors; officers; those

More information

Insider Trading Policy

Insider Trading Policy Purpose U.S. federal and state and Canadian provincial securities laws prohibit buying, selling, or making other transfers of securities by persons who have material information that is not generally known

More information

INSIDER TRADING POLICY

INSIDER TRADING POLICY INSIDER TRADING POLICY NOVEMBER 2014 2 INSIDER TRADING POLICY NOVEMBER 2014 This Policy provides guidelines for directors, officers, executives, employees and consultants (collectively, WSP Team Members

More information

THE CROATIAN PARLIAMENT DECISION PROMULGATING THE ACT ON INVESTMENT FUNDS WITH A PUBLIC OFFERING

THE CROATIAN PARLIAMENT DECISION PROMULGATING THE ACT ON INVESTMENT FUNDS WITH A PUBLIC OFFERING THE CROATIAN PARLIAMENT Pursuant to Article 89 of the Constitution of the Republic of Croatia, I hereby pass the DECISION PROMULGATING THE ACT ON INVESTMENT FUNDS WITH A PUBLIC OFFERING I hereby promulgate

More information

Act on the Supervision of Credit Institutions, Insurance Companies and Securities Trading etc. (Financial Supervision Act)

Act on the Supervision of Credit Institutions, Insurance Companies and Securities Trading etc. (Financial Supervision Act) KREDITTILSYNET Norway Translation updated August 2003 Translated by Government Authorised Translator Peter Thomas This translation is for information purposes only. Legal authenticity remains with the

More information

Federal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector 1

Federal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector 1 English is not an official language of the Swiss Confederation. This translation is provided for information purposes only and has no legal force. Federal Act on Combating Money Laundering and Terrorist

More information

Act on the Supervision of Financial Institutions etc. (Financial Supervision Act)

Act on the Supervision of Financial Institutions etc. (Financial Supervision Act) FINANSTILSYNET Norway Translation update January 2013 This translation is for information purposes only. Legal authenticity remains with the official Norwegian version as published in Norsk Lovtidend.

More information

Security Trading Policy: Trading Restrictions

Security Trading Policy: Trading Restrictions Security Trading Policy: Trading Restrictions SCENTRE GROUP LIMITED ABN 66 001 671 496 SCENTRE MANAGEMENT LIMITED ABN 41 001 670 579 AFS Licence No: 230329 as responsible entity of Scentre Group Trust

More information

Credit Services Organization Act 24 O.S. 131 148

Credit Services Organization Act 24 O.S. 131 148 Credit Services Organization Act 24 O.S. 131 148 Chapter 8 Credit Services Organization Act Section 131 Short Title This act shall be known and may be cited as the "Credit Services Organization Act". Added

More information

Title: Code for Dealing in Securities

Title: Code for Dealing in Securities GSK Policy Title: Code for Dealing in Securities Official Short Title: Code for Dealing in Securities Key Points No employee may deal in GlaxoSmithKline plc securities ( GSK securities ) if he or she is

More information

SECURITIES TRADING AND INSIDER REPORTING POLICY

SECURITIES TRADING AND INSIDER REPORTING POLICY SECURITIES TRADING AND INSIDER REPORTING POLICY Securities law generally prohibits trading or dealing in the securities of a company on the basis of undisclosed material information. Anyone violating these

More information

SEAFIELD RESOURCES LTD. (the Corporation ) Insider Trading Policy

SEAFIELD RESOURCES LTD. (the Corporation ) Insider Trading Policy SEAFIELD RESOURCES LTD. (the Corporation ) Insider Trading Policy 1. Introduction The Board of Directors of the Corporation 1 has determined that the Corporation should formalize its policy on securities

More information

TRADING POLICY AND GUIDELINES

TRADING POLICY AND GUIDELINES TRADING POLICY AND GUIDELINES July 2015 1. Application of the Policy Introduction This Policy has been designed to prevent improper trading by employees, senior managers and directors of NZX Limited (

More information

REGULATION OF INVESTMENT COUNSELING, INVESTMENT MARKETING AND PORTFOLIO MANAGEMENT LAW 5757-1997

REGULATION OF INVESTMENT COUNSELING, INVESTMENT MARKETING AND PORTFOLIO MANAGEMENT LAW 5757-1997 Disclaimer: The Following is an unofficial translation, and not necessarily an updated one. The binding version is the official Hebrew text. Readers are consequently advised to consult qualified professional

More information

A I M R U L E S F O R C O M PA N I E S F E B R U A R Y 2 0 0 7

A I M R U L E S F O R C O M PA N I E S F E B R U A R Y 2 0 0 7 A I M R U L E S F O R C O M PA N I E S F E B R U A R Y 2 0 0 7 AIM Rules for Companies Introduction 2 Part One AIM Rules 3 Retention and role of a nominated adviser 3 Applicants for AIM 3 Special conditions

More information

AUSTOCK GROUP LTD POLICY IN RELATION TO SHARE TRADING

AUSTOCK GROUP LTD POLICY IN RELATION TO SHARE TRADING AUSTOCK GROUP LTD POLICY IN RELATION TO SHARE TRADING 1. Purpose 1.1 The purpose of this policy is to: (1) explain the type of conduct that is prohibited under the Corporations Act 2001 (as amended) in

More information

Act on Investment Firms 26.7.1996/579

Act on Investment Firms 26.7.1996/579 Please note: This is an unofficial translation. Amendments up to 135/2007 included, May 2007. Act on Investment Firms 26.7.1996/579 CHAPTER 1 General provisions Section 1 Scope of application This Act

More information

NETFLIX, INC. INSIDER TRADING POLICY

NETFLIX, INC. INSIDER TRADING POLICY Insider Trading Policy (20150806) NETFLIX, INC. INSIDER TRADING POLICY In order to take an active role in the prevention of insider trading violations by officers, directors, employees and other related

More information

QUESTERRE ENERGY CORPORATION (the Corporation ) INSIDER TRADING AND REPORTING POLICY

QUESTERRE ENERGY CORPORATION (the Corporation ) INSIDER TRADING AND REPORTING POLICY QUESTERRE ENERGY CORPORATION (the Corporation ) INSIDER TRADING AND REPORTING POLICY The purpose of this insider policy is to summarize the insider trading restrictions to which directors, officers, consultants

More information

Securities Dealing Policy

Securities Dealing Policy Securities Dealing Policy WorleyParsons Limited Revision: 24 February 2015 Adopted: 24 February 2015 Level 12, 141 Walker Street Sydney NSW 2060 Australia Tel: +61 2 8923 6866 Fax: +61 2 8923 6877 Web:

More information

QIAGEN N.V. Corporate Governance

QIAGEN N.V. Corporate Governance 118 QIAGEN N.V. Corporate Governance Corporate Governance 119 Corporate Governance Decl ar ation of Com pliance of Q IAGEN N.V. regarding the Ger m an Corpor ate Governance Code In QIAGEN s 2001 Annual

More information

ALTERNATIVE TRADING SYSTEM RULES

ALTERNATIVE TRADING SYSTEM RULES ALTERNATIVE TRADING SYSTEM RULES (text according to legal condition at 20 June 2012) 1 NOTE: Only the Polish version of this document is legally binding. This translation is provided for information only.

More information

AMP Limited Trading Policy

AMP Limited Trading Policy AMP Limited Trading Policy Approved by the AMP Limited Board on 28 March 2012 AMP Limited ABN 49 079 354 519 Contents 1. Trading Policy... 3 1.1 Guiding principles... 3 1.2 General trading restrictions

More information

Each member of the Board confirms that he or she has acquainted himself or herself with:

Each member of the Board confirms that he or she has acquainted himself or herself with: DIRECTOR'S CHARTER (Established by the Board of Directors on 18 November 2003 and amended by the respective Boards of Directors on 27 January 2005, 26 November 2009, 25 November 2010, 24 November 2011,

More information

Share Trading Policy. Policy Number: P2.1. 4. Clearance to Deal. 2. Who this Policy Applies to

Share Trading Policy. Policy Number: P2.1. 4. Clearance to Deal. 2. Who this Policy Applies to Share Trading Policy Policy Number: P2.1 Date Approved: 01 October 2015 Employee Responsible: CFO Approved By: MMI Board 1. Purpose of this Policy 1.1. This trading policy (Policy) is intended to ensure

More information

Securities Trading Policy

Securities Trading Policy Securities Trading Policy Chalice Gold Mines Limited ACN 116 648 956 (Company) 1 Purpose The purpose of this policy is to: assist those persons covered by the policy to comply with their obligations under

More information

INSIDER TRADING POLICY

INSIDER TRADING POLICY U.S. Federal securities laws prohibit: INSIDER TRADING POLICY the purchase or sale of securities by persons who are aware of material nonpublic information about a company, and/or the disclosure of material

More information

CIVITAS SOLUTIONS, INC. INSIDER TRADING POLICY September 17, 2014. Adoption of Insider Trading Policy. Background

CIVITAS SOLUTIONS, INC. INSIDER TRADING POLICY September 17, 2014. Adoption of Insider Trading Policy. Background CIVITAS SOLUTIONS, INC. INSIDER TRADING POLICY September 17, 2014 This policy applies to all directors, officers and employees of Civitas Solutions, Inc. and its subsidiaries (the Company ), and to consultants

More information

JB Hi-Fi Limited Securities Trading Policy

JB Hi-Fi Limited Securities Trading Policy JB Hi-Fi Limited Securities Trading Policy 1. Introduction and scope of this Policy Purpose and objectives 1.1 This document sets out the securities trading policy (Policy) of JB Hi-Fi Limited (JB Hi-

More information

Chapter 3 Financial Year

Chapter 3 Financial Year [PART 6 FINANCIAL STATEMENTS, ANNUAL RETURN AND AUDIT Chapter 1 Preliminary 269. What this Part contains and use of prefixes - Companies Act and IFRS. 270. Overall limitation on discretions with respect

More information

Act on the Protection of Privacy in Working Life (759/2004)

Act on the Protection of Privacy in Working Life (759/2004) NB: Unofficial translation Ministry of Labour, Finland Chapter 1 - General provisions Section 1 Purpose of the act Act on the Protection of Privacy in Working Life (759/2004) The purpose of this Act is

More information

The Warsaw Stock Exchange Rules

The Warsaw Stock Exchange Rules (text consolidated at 20 June 2012)* * 1) The Rules adopted by the Supervisory Board by Resolution No. 1/1110/2006 dated 4 January 2006, as amended by the Exchange Supervisory Board: - by Resolution No.

More information

AIM Rules for Companies. January 2016

AIM Rules for Companies. January 2016 AIM Rules for Companies January 2016 1 AIM Rules for Companies Introduction 3 Part One AIM Rules 4 Retention and role of a nominated adviser Applicants for AIM 4 4 Special conditions for certain applicants

More information

Trading Rules of the Georgian Stock Exchange

Trading Rules of the Georgian Stock Exchange A p p r o v e d : by the General Meeting of JSC Georgian Stock Exchange Minutes # 4, September 26, 1999 Changes and amendments are made: by the Supervisory Board of JSC Georgian Stock Exchange Minutes

More information

DE NEDERLANDSCHE BANK N.V

DE NEDERLANDSCHE BANK N.V 1 DE NEDERLANDSCHE BANK N.V Policy Rule on Scope of Consolidated and Solo Supervision of Investment Firms and Credit Institutions under the Financial Supervision Act Policy Rule of De Nederlandsche Bank

More information