One Managed Investment Funds Limited. Adopted by the Board on 22 August 2014

Size: px
Start display at page:

Download "One Managed Investment Funds Limited. Adopted by the Board on 22 August 2014"

Transcription

1 One Managed Investment Funds Limited Policy Name: Securities Trading Policy Adopted by the Board on 22 August 2014

2 1. Introduction The One Investment Group and its controlled entities, hereafter OIG, including One Managed Investment Funds Limited ABN (OMIFL) in its capacity as responsible entity of Agricultural Land Trust ARSN , ASX Code: AGJ) are committed to ensuring that public confidence is maintained in its personnel and the trading of securities of funds of which an OIG entity is the responsible entity, trustee and/or custodian. This document describes in relation to OIG the circumstances in which it seeks to restrict the dealing in Financial Products by its directors and staff. This policy is designed to provide protection to OIG, its related parties and its staff, by restricting dealings in Financial Products during certain times, or when individuals are in possession of certain types of information. It is also designed to preserve the reputation of OIG, its related parties and its staff in public markets, and is designed to be consistent with best practice in this area. OIG expects all staff members to act with integrity and honesty at all times. It is crucial that each staff member recognises their responsibilities set out in this policy. Adherence to this policy is a key component of OIG s risk management processes. 2. Definitions In this policy: Associate means any person in respect of whom a Staff Member has the ability to control or influence decisions in relation to Financial Products, and includes the following: a) a spouse, de facto partner, child or step-child (being a son or daughter under the age of 18 years) of the Staff Member (Immediate Family); b) a self-managed superannuation fund for the Staff Member or his or her Immediate Family; c) a private company of which the Staff Member or his or her Immediate Family is a director; and d) a trust in which the Staff Member or his or her Immediate Family is a beneficiary. Deal or Dealing in a Financial Product includes: a) buying, selling, otherwise acquiring or disposing of a Financial Product or part of a Financial Product and entering into a contract, agreement or deed under which a Financial Product is created; and b) entering into a transaction with respect to a Financial Product that is designed or intended to hedge, limit or extend the economic risks in that Financial Product (whether by way of swap or derivative or otherwise). External Committee Member means a person, who is not a Staff Member, engaged by a responsible entity (as defined in section 9 of the Corporations Act), 1

3 that is a subsidiary of OIG, to act as an external member of a compliance committee that is established by the Responsible Entity pursuant to Part 5C.5 of the Corporations Act. Financial Products means Division 3 financial products (as defined in Division 3 of Part 7.10 of the Corporations Act 2001) and therefore includes (but is not limited to): a) securities; b) derivatives; c) interests in a managed investment scheme; d) other financial products that are able to be traded on a financial market; and e) where appropriate for the purposes of this policy, OIG Financial Products. Inside Information means information that: a) is not generally available; and b) is price or value sensitive. In other words, if the information were made publicly available, it would have a material effect on the price or value of a Financial Product. Non-OIG Financial Products means Financial Products other than OIG Financial Products. Non-Executive Director or NED means a director of any OIG company who is not employed by OIG. OIG means One Investment Group Pty Limited and each subsidiary of One Investment Group Pty Limited. OIG Financial Products means all Financial Products issued by (or derivatives with respect to any Financial Products issued by) OIG or any entity managed by OIG. Permitted Period means the period of one calendar month after the relevant entities: a) annual general meeting; b) announcement of half-year or yearly results; or c) issue of a prospectus or product disclosure statement offering a OIG Financial Product (or a document containing equivalent information). Staff Member means all OIG employees, officers and directors (including Non-Executive Directors and External Committee Members) regardless of their seniority, division or geographical location, and includes contractors. In addition, an employee includes any short-term contractors, consultants or temporary staff members. A reference to a Staff Member in this policy includes a reference to an Associate of that Staff Member. 2

4 3. Application This policy applies to all Staff Members. It also applies to dealings in Financial Products by Associates of Staff Members. 4. Guiding Principles i). Dealing in OIG Financial Products by Staff Members Subject to limited exceptions, Staff Members may only deal in OIG Financial Products: during a Permitted Period; if they have first obtained pre-clearance from OIG Compliance; if the Financial Products have been held for at least 3 months; and if they are not in possession of Inside Information relating to the Financial Products. In addition, dealings are permitted within the initial 3 month period following the acquisition of an OIG Financial Product if those OIG Financial Products are being transferred to an Associate of the Staff Member, however, any such transfers MUST be made off-market and are subject to the pre-clearance condition above. Staff Members may not enter into a transaction that is designed or intended to hedge that Staff Member s exposure to an OIG Financial Product which is subject to retention arrangements, an unvested entitlement under an OIG Employee Incentive scheme or both. Also, OIG s NEDs may not enter into transactions that operate to limit the economic risk of their OIG Financial Product shareholding below their minimum shareholding requirement. Refer Section 4 below for more information. ii). Dealing in Non-OIG Financial Products by Staff Members Subject to limited exceptions, staff members (other than NEDs and External Committee Members) may only deal in Non-OIG Financial Products: if they have first obtained pre-clearance from OIG Compliance; and if they are not in possession of Inside Information relating to the Financial Products. Refer to Section 5 below for more information. iii). Dealing in Non-OIG Financial Products by NEDs and External Committee Members NEDs and External Committee Members do not need pre-clearance before dealing in Non-OIG Financial Products but remain subject to the general trading restriction if in possession of Inside Information relating to the Financial Products. 3

5 iv). Dealing by Associates Staff Members are personally responsible for ensuring that their Associates do not deal in Financial Products in circumstances where, because of this policy, the Staff Member would be prohibited from dealing in those Financial Products. v). Dealing by Others In addition to the restrictions imposed by this policy, Staff Members are reminded that the Corporations Act also prevents a person who is in possession of Inside Information from procuring another person from dealing in Financial Products. If you are in possession of Inside Information or if you are not permitted to deal as a result of the application of this policy, you may not procure a third party to deal either on your behalf or on their own account. vi). Margin Loans No Staff Member may enter into a margin loan arrangement in respect of an OIG Financial Product. This restriction is limited to arrangements properly described as margin lending arrangements and does not extend to other types of loan arrangements or instruments which may be secured by a security interest granted in respect of OIG Financial Products. Staff Members may enter into or acquire such other types of loan arrangements or instruments, but only after first notifying OIG Compliance of their intention to do so and disclosing the terms of such loan arrangements or instruments. Staff Members should consult with the OIG Compliance Director if they are uncertain as to whether an arrangement is properly classified as a margin lending arrangement. 5. OIG Financial Products Staff Members must not deal in OIG Financial Products without first obtaining preclearance from OIG Compliance. A request for pre-clearance should be sent by to Refer to Section 6 for pre-clearance rules. These conditions do not apply if: in relation to the acquisition of OIG Financial Products by Staff Members or NEDs under certain Incentive Schemes or Employment Contract scenarios, the OIG Board has authorised the proposed dealing; or in relation to Staff Members (other than the Managing Director), the Managing Director has authorised the proposed dealing in writing; or in relation to the Managing Director, the Compliance Committee has authorised the proposed dealing. 4

6 Such authorisation may only be given in very limited cases (eg. extreme hardship) and will usually permit only the sale, not the purchase, of OIG Financial Products. It should be noted that even if the above conditions are met or an exception applies, no dealing in OIG Financial Products will be allowed if a Staff Member is in possession of Inside Information affecting the relevant Financial Product(s). 6. Non-OIG Financial Products General Staff Members (other than NEDs and External Committee Members) must not deal in any Non-OIG Financial Products without first obtaining pre-clearance from OIG Compliance. A request for pre-clearance should be sent by to The following rules apply to dealings which have been pre-cleared: the order relating to the dealing must be given within 7 days of receipt of the pre clearance; the order must be carried out within 30 days of receipt of the pre-clearance; and any part of the order that is not executed within 30 days of receipt of the pre-clearance must be pre-cleared again. Because pre-clearance is required for every dealing, some transactions will require more than one pre-clearance. For example, both the acquisition and exercise of an option will require pre-clearance. OIG Compliance will usually grant pre-clearance unless a dealing involves Financial Products which are embargoed. OIG Compliance cannot grant pre-clearance in relation to embargoed Financial Products except in exceptional cases. OIG Compliance has discretion to accept or reject pre-clearance in all cases. Pre-clearance is not a warranty of the proposed dealing s propriety by OIG or its related parties. It is incumbent upon each Staff Member to ensure that each dealing they conduct complies with all applicable laws and regulations. Pre-clearance is a discretion and approval can be withdrawn at any time by notice to the relevant Staff Members. Embargo Some Financial Products or issuers of Financial Products may be placed on embargo in relation to Staff Members. Embargo is generally imposed when it is suspected that there is or there is a risk that a Staff Member or group of Staff Members are in possession of Inside Information in relation to particular Financial Products or an issuer of Financial Products. 5

7 A Staff Member (other than NEDs) who knows or suspects that another Staff Member, entity or Financial Product has been placed on embargo is prohibited from disclosing that information to any other person (including other Staff Members). Staff Members may apply for a waiver from embargo. Such waivers will only be granted in exceptional circumstances. A written submission must be provided to OIG Compliance in which the Staff Member: states that they do not possess any information that is not generally available and that is price or value sensitive to the relevant Financial Products; states that they face financial hardship and describes the hardship; and explains why dealing in the relevant Financial Product is the only practical method of overcoming the financial hardship. Waivers will usually be granted only in relation to the sale, not the purchase, of Financial Products. 7. Avoiding Market Misconduct Inside Information If a Staff Member possesses Inside Information in relation to a Financial Product they are prohibited from dealing in that Financial Product or advising or procuring others to deal in that Financial Product even if they have obtained pre-clearance. This is an overriding prohibition of the Corporations Act and operates at all times and in respect of all dealings in Financial Products by all Staff Members. Examples of Inside Information To illustrate the prohibition described above, the following are possible examples of price sensitive information which, if not generally available, may constitute Inside Information: a change in an entity's forecast or expectation; a proposed major acquisition or disposal of assets; a proposed or actual takeover; a significant new development proposal; the likely granting (or loss) of a major contract or government approval; a proposed distribution or change in distribution policy; a proposed new issue of securities; and a significant change in senior management of the entity or of another entity. The above is not an exhaustive list of Inside Information. Information is 'generally available' (and therefore does not constitute Inside Information) where the information: is readily observable; or 6

8 has been brought to the attention of investors by an ASX announcement or similar communication made to the general public and a reasonable period for its dissemination has elapsed since the announcement; or is able to be deduced, concluded or inferred from other generally available information. Whether information is Inside Information may sometimes be unclear. To avoid reputation or possible legal issues, a Staff Member should consult in writing with the executive directors of OIG and/or OIG General Counsel prior to any dealing. Market Manipulation A Staff Member must not take part in, or carry out a transaction that has or is likely to have the effect of creating an artificial price for trading in Financial Products on a financial market; or maintaining at a level that is artificial, a price for trading in Financial Products on a financial market. Creating a false or misleading appearance of active trading A Staff Member must not do, or omit to do, an act which is likely to have the effect of creating, or causing the creation of, a false or misleading appearance of active trading in Financial Products on a financial market; or with respect to the market for, or the price for trading in, Financial Products on a financial market. A Staff Member is taken to have created a false or misleading appearance of active trading in particular Financial Products on a financial market if the Staff Member: enters into, or carries out, either directly or indirectly, any transaction or acquisition or disposal of any of those Financial Products that does not involve any change in the beneficial ownership of the products; or makes an offer to acquire or to dispose of any of those Financial Products in the following circumstances: o the offer is to acquire or to dispose of at a "specified price"; and o the Staff Member has made or proposes to make, or knows that an Associate of the Staff Member has made or proposes to make an offer to acquire or to dispose of the same number (or substantially the same number) of those Financial Products at a price that is substantially the same as the specified price referred to in the previous paragraph. False Trading & Market Rigging A Staff Member must not enter into, or engage in, a fictitious or artificial transaction or device if that transaction or device results in: the price for trading in Financial Products on a financial market being maintained, inflated or depressed; or fluctuations in the price for trading in Financial Products on a financial market. 7

9 8. Exceptions to Policy Subscribing for a new issue through a prospectus Staff Members may apply for Financial Products offered through a prospectus or product disclosure statement without obtaining pre-clearance. Offers of firm allocation in a new issue by OIG Staff Members need not obtain pre-clearance before applying for new issues of Financial Products offered by OIG as part of a firm allocation (i.e. an allocation specifically to Staff Members). Staff Members should nevertheless consider whether their participation in such issues complies with applicable laws and regulations. The participation of Staff Members in any such offer is at the discretion of the OIG board. The take-up of entitlements Staff Members may take up entitlements under a rights issue or other offer made to all security holders of a particular entity including the participation in any dividend or distribution reinvestment plan. Undertakings to accept, or the acceptance of, a takeover Staff Members may participate in a public takeover when an offer is made to all security holders of a particular entity. Exercise of option or right, or conversion of securities outside permitted periods The exercise of an option or right under an employees share scheme, or the conversion of a convertible security, where the final date for the exercise of such option or right, or conversion of such security, falls outside any Permitted Period and the director could not reasonably have been expected to exercise during a Permitted Period. Securities acquired pursuant to such exercise or conversion is subject to the usual rules described in this policy for dealing in securities. Trading in Financial Products that does not involve discretion by the Staff Member Staff Members are not required to obtain clearance under this policy if they are investing into a managed fund or a form of discretionary fund which does not involve the selection of the securities by the Staff Member (for example, a sector specific fund or a pure discretionary trading account with a broker). It should be noted that this exception does not apply to OIG Financial Products where staff operate discretionary trading accounts with a broker. If in doubt, please contact OIG Compliance prior to any dealing. 8

10 9. Sub-underwriting OIG Issues/Offers Staff Members and their Associates are not permitted to enter into a sub-underwriting arrangement with the underwriter of an OIG or OIG associated issue of Financial Products. Applications for shares in OIG associated issues should only be via staff allocations and are subject to the staff allocation policy. This restriction aims to ensure the impartiality of Staff Members in relation to decisions regarding pricing and underwriting on OIG related issues. 10. Consequences of breaching this policy Adhering to the policies and standards of conduct discussed in this policy is one of the conditions of employment with OIG. Failure to comply with them may result in a Staff Member being subject to disciplinary action. In extreme cases, the Staff Member may be dismissed. In addition, violation of the rules described in this policy may subject an employee to civil or criminal penalties under applicable laws and regulations. 11. Questions Any questions concerning the interpretation or application of this policy, the propriety of any conduct relating to personal dealing or other compliance related matters should be referred to OIG Compliance. 12. Monitoring of compliance The implementation and monitoring of compliance by all employees of and consultants or contractors to any of the relevant entities is undertaken by the Compliance Officer (and, if they are different persons at any time, the Privacy Officer). 13. Review of Policy Annual Review This policy is to be reviewed not less than every 12 months. It must also be reviewed whenever there is a significant change in the law which may affect the substance of this policy. Responsibility The Compliance Officer (and, if they are different persons at any time, the Privacy Officer) must report to the board not less than every 12 months as to compliance. 9

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

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

This statement sets out the policy of Amcor Limited ( Amcor ) for trading in Securities of Amcor. It applies to:

This statement sets out the policy of Amcor Limited ( Amcor ) for trading in Securities of Amcor. It applies to: Share Trading Policy SHARE TRADING POLICY Trading in securities of Amcor Limited 1. Overview and Definitions This statement sets out the policy of Amcor Limited ( Amcor ) for trading in Securities of Amcor.

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

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

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

Securities Trading Policy

Securities Trading Policy Securities Trading Policy APA Group Securities Trading Page 1 of 12 Contents 1 Purpose... 3 2 Coverage / Scope... 3 3 Values & Commitments... 3 4 Policy... 3 5 Links / interaction with other policies...

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

Securities Trading Policy

Securities Trading Policy Securities Trading Policy APN Outdoor Group Limited (ACN 155 848 589) Adopted by the Board on 17 October 2014 APN Outdoor Group Limited Securities Trading Policy 1 Purpose The Corporations Act 2001 (Cth)

More information

SECURITY TRADING POLICY Approved 24 December 2010

SECURITY TRADING POLICY Approved 24 December 2010 1. Introduction and Policy Statement ATTICUS RESOURCES LIMITED ABN 34 124 782 038 SECURITY TRADING POLICY Approved 24 December 2010 The ordinary shares of ( Atticus ) are listed on ASX. Atticus aims to

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

Share Trading Policy. Spotless Group Holdings Limited ACN 154 229 562

Share Trading Policy. Spotless Group Holdings Limited ACN 154 229 562 Share Trading Policy Spotless Group Holdings Limited ACN 154 229 562 Adopted by the Company board on 26 March 2014 Contents Page 1 Introduction 1 2 Persons to whom this Policy applies 1 3 Purpose 1 4 Restrictions

More information

Probiotec Limited. Security Trading Policy

Probiotec Limited. Security Trading Policy Probiotec Limited Security Trading Policy TABLE OF CONTENTS Page no. 1 Definitions... 1 2 Introduction... 2 3 Insider Trading... 3 4 Scope of this Policy... 3 5 Periods During Which Dealings Must Not Take

More information

SECURITY TRADING POLICY

SECURITY TRADING POLICY 3D Medical Limited ABN: 26 007 817 192 SECURITY TRADING POLICY Introduction This document sets out the Company s policy on the sale and purchase of its securities by its Directors, employees and contractors.

More information

HARVEY NORMAN HOLDINGS LIMITED A.C.N. 003 237 545 (the "Company") SHARE TRADING POLICY

HARVEY NORMAN HOLDINGS LIMITED A.C.N. 003 237 545 (the Company) SHARE TRADING POLICY HARVEY NORMAN HOLDINGS LIMITED A.C.N. 003 237 545 (the "Company") SHARE TRADING POLICY 1. BACKGROUND AND DEFINITIONS 1.1 The Company is a public company, listed on the ASX. 1.2 The Company is committed

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

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

Hotel Property Investments Limited Security Trading Policy

Hotel Property Investments Limited Security Trading Policy Hotel Property Investments Limited Security Trading Policy Arnold Bloch Leibler TABLE OF CONTENTS 1 Definitions... 3 2 Introduction... 4 3 Insider Trading... 5 4 Scope of this Policy... 5 5 Periods During

More information

Share Trading Policy GWA007

Share Trading Policy GWA007 GWA007 Created By Executive Director Date February 2005 Rev. No. 4 Updated By Executive Director Date December 2011 File Name Share Trading Policy GWA007 Approved By GWA Group Limited Board of Directors

More information

SHARE TRADING POLICY

SHARE TRADING POLICY SHARE TRADING POLICY 1. Background 1.1 Murchison Holdings Limited ( MCH ) has adopted a corporate governance policy taking into account: 1.1.1 the Corporations Act 2001 (Cth); 1.1.2 the guidelines set

More information

Security Trading Policy

Security Trading Policy Security Trading Policy Grays ecommerce Group Limited (ACN 125 736 914) (Grays or Company) Adopted by the Board on 1. Introduction 1.1 Purpose This policy summarises the law relating to insider trading

More information

Securities Trading Policy

Securities Trading Policy Securities Trading Policy Securities trading Page 1 of 9 Contents 1 Purpose... 3 2 Coverage / Scope... 3 3 Values & Commitments... 3 4 Policy... 3 5 Links / interaction with other policies... 9 6 Attachments...

More information

Securities Trading Policy

Securities Trading Policy Securities Trading Policy Securities Trading Policy Prana Biotechnology Ltd 1 Purpose This securities trading policy (Policy) sets out the policy of the Company regarding the trading in Company securities.

More information

FLEXIROAM LIMITED ( COMPANY ) (ACN 143 777 397) SECURITY TRADING POLICY ( POLICY )

FLEXIROAM LIMITED ( COMPANY ) (ACN 143 777 397) SECURITY TRADING POLICY ( POLICY ) FLEXIROAM LIMITED ( COMPANY ) (ACN 143 777 397) SECURITY TRADING POLICY ( POLICY ) 1. Introduction 1.1 This document sets out the Company s policy on the sale and purchase of its securities by its Directors,

More information

Security Trading Policy!

Security Trading Policy! Catapult Group International Ltd Security Trading Policy Arnold Bloch Leibler Ref: MD:JAV 011754022 ABL/3701687v1 TABLE OF CONTENTS Page no. 1. Definitions... 3 2. Introduction... 4 3. Insider Trading...

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

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

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

HGL Limited Security Trading policy

HGL Limited Security Trading policy HGL Limited Security Trading policy 1. Introduction 1.1. The ordinary shares of HGL are listed on the ASX under listing code HNG. HGL aims to achieve the highest possible standards of corporate conduct

More information

Share Trading Policy. Yancoal Australia Limited ACN 111 859 119

Share Trading Policy. Yancoal Australia Limited ACN 111 859 119 Share Trading Policy Yancoal Australia Limited ACN 111 859 119 Adopted by the Board on 15 June 2012 Policy 1 Objective The purpose of this Policy is to establish a best practice procedure for ensuring

More information

Telephone (03) 8646 6444 Facsimile (03) 8646 6441 ABN 66 005 585 811

Telephone (03) 8646 6444 Facsimile (03) 8646 6441 ABN 66 005 585 811 Level 15, 380 St Kilda Road Melbourne VIC 3004 www.skilledgroup.com.au Telephone (03) 8646 6444 Facsimile (03) 8646 6441 ABN 66 005 585 811 23 December 2010 Manager Companies Company Announcements Office

More information

SECURITIES TRADING POLICY

SECURITIES TRADING POLICY 1. INTRODUCTION 1.1 Purpose The Board of Transpacific Industries Group Ltd (TPI) considers it essential that TPI and its employees comply with both the law and high ethical standards at all times. Insider

More information

PURPOSE OF THIS POLICY

PURPOSE OF THIS POLICY BACKGROUND Transfield Services Limited (Transfield Services) is a public company, whose shares are listed on the Australian Securities Exchange (ASX). Transfield Services is committed to responsible corporate

More information

Macquarie Group Limited Trading Policy

Macquarie Group Limited Trading Policy = = Macquarie Group Limited Trading Policy This Policy sets out the trading restrictions that apply to trading in Macquarie securities (as defined in this Policy) by Macquarie Employees, including Key

More information

SHARE TRADING POLICY Asciano Limited

SHARE TRADING POLICY Asciano Limited SHARE TRADING POLICY Asciano Limited ABN 26 123 652 862 UPDATES 4 June 2007 Adopted by the Board 22 July 2008 Reviewed and minor amendments made 22 September 2009 Reviewed and minor amendments made 25

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

BARRA RESOURCES LIMITED SECURITIES TRADING POLICY

BARRA RESOURCES LIMITED SECURITIES TRADING POLICY BARRA RESOURCES LIMITED SECURITIES TRADING POLICY 1.0 Introduction The Board of Barra Resources Limited ("Barra") has adopted the following policy in relation to directors, officers, employees and Potential

More information

SHARE TRADING POLICY

SHARE TRADING POLICY SHARE TRADING POLICY 1. PURPOSE AND SCOPE 1.1 Terramin Australia Limited (Terramin) is a public company, listed on the Australian Securities Exchange (ASX). Terramin is committed to upholding high standards

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

In accordance with Listing Rule 12.10, Computershare Limited attaches its updated Share Trading Policy.

In accordance with Listing Rule 12.10, Computershare Limited attaches its updated Share Trading Policy. MARKET ANNOUNCEMENT Computershare Limited ABN 71 005 485 825 Yarra Falls, 452 Johnston Street Abbotsford Victoria 3067 Australia PO Box 103 Abbotsford Victoria 3067 Australia Telephone 61 3 9415 5000 Facsimile

More information

Share Trading Policy. Dealing Rules for Directors and Senior Executives. Summary

Share Trading Policy. Dealing Rules for Directors and Senior Executives. Summary Share Trading Policy Dealing Rules for Directors and Senior Executives Summary The Board encourages directors and senior executives (key management personnel (KMP s)) to own shares in the Company to further

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

QBE INSURANCE GROUP LIMITED

QBE INSURANCE GROUP LIMITED QBE INSURANCE GROUP LIMITED Trading Policy for dealing in securities of QBE Insurance Group Limited or other entities April 2015 QBE Trading Policy.docx Page 1 Contents 1. Definitions 2. Statutory prohibitions

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

Eclipx Group Limited Securities Trading

Eclipx Group Limited Securities Trading Eclipx Group Limited Securities Trading Date approved: 26 March 2015 SECURITIES TRADING ECLIPX GROUP LIMITED (THE COMPANY) 1. Introduction and Purpose 1.1 Background This Securities Trading Policy (Policy)

More information

Designated Officer means a director or person engaged in the management of the Company, whether as an employee or consultant.

Designated Officer means a director or person engaged in the management of the Company, whether as an employee or consultant. ACN 111 082 485 ASX: MKB NASDAQ: MOKO T: +61 2 9299 9690 F: +61 2 9299 9629 Suite 4, Level 9, 341 George Street Sydney NSW, 2000, Australia MOKOsocialmedia.com contact@moko.mobi MOKO Social Media Limited

More information

Securities Trading Policy

Securities Trading Policy M2 Group Ltd Securities Trading Policy 1. Purpose and Objective 1.1 M2 is a listed public company. The ASX Listing Rules require M2 to: (d) (e) have a securities trading policy to regulate the Dealing

More information

CALTEX AUSTRALIA LIMITED ACN 004 201 307 SECURITIES TRADING POLICY

CALTEX AUSTRALIA LIMITED ACN 004 201 307 SECURITIES TRADING POLICY CALTEX AUSTRALIA LIMITED ACN 004 201 307 SECURITIES TRADING POLICY Introduction 1. Directors, employees and contractors of listed companies may receive or possess inside information that is not generally

More information

All Directors and employees of Queste and its subsidiaries (if any) (Queste Group); and Contractors who have agreed to be bound by this policy.

All Directors and employees of Queste and its subsidiaries (if any) (Queste Group); and Contractors who have agreed to be bound by this policy. Share Trading Policy Policy Summary What this Policy covers Buying and selling Queste shares. Who this Policy applies to All Directors and employees of Queste and its subsidiaries (if any) (Queste Group);

More information

EUREKA GROUP HOLDINGS LIMITED SECURITY TRADING POLICY

EUREKA GROUP HOLDINGS LIMITED SECURITY TRADING POLICY EUREKA GROUP HOLDINGS LIMITED SECURITY TRADING POLICY 1. INTRODUCTION 1.1 This policy summarises the law relating to insider trading and sets out the Company s trading policy on buying and selling the

More information

ABM Resources NL Security Trading Policy

ABM Resources NL Security Trading Policy ABM Resources NL Security Trading Policy 1. INTRODUCTION 1.1 The ordinary shares of ABM Resources NL (ABM) are listed on ASX. ABM aims to achieve the highest possible standards of corporate conduct and

More information

CRYOSITE LIMITED PERSONNEL SHARE TRADING POLICY

CRYOSITE LIMITED PERSONNEL SHARE TRADING POLICY 1 OVERVIEW The Corporations Act, and the laws of other jurisdictions in which Cryosite operates contain provisions which prohibit a person in possession of material, non public information ( Material Information

More information

In accordance with Listing Rule 12.10, Treasury Wine Estates Limited attaches a revised Share Trading Policy.

In accordance with Listing Rule 12.10, Treasury Wine Estates Limited attaches a revised Share Trading Policy. 28 May 2015 ASX Market Announcements Office Via: Online Lodgement Revised In accordance with Listing Rule 12.10, Treasury Wine Estates Limited attaches a revised. Yours faithfully Paul Conroy Chief Legal

More information

Share Trading Policy. Australian Careers Network Limited ACN 168 592 434. Doc ID 165479751/v2

Share Trading Policy. Australian Careers Network Limited ACN 168 592 434. Doc ID 165479751/v2 Share Trading Policy Australian Careers Network Limited ACN 168 592 434 Ref 304685 Level 14, Australia Square, 264-278 George Street, Sydney Telephone +61 2 9334 8555 NSW 2000 Australia GPO Box 5408, Sydney

More information

1 December 2014. The Manager Company Announcements Office Australian Securities Exchange 20 Bridge Street SYDNEY NSW 2000.

1 December 2014. The Manager Company Announcements Office Australian Securities Exchange 20 Bridge Street SYDNEY NSW 2000. 1 December 2014 The Manager Company Announcements Office Australian Securities Exchange 20 Bridge Street SYDNEY NSW 2000 Level 10, 111 Pacific Highway North Sydney NSW 2060 Locked Bag 917 North Sydney

More information

SHARE TRADING POLICY

SHARE TRADING POLICY SHARE TRADING POLICY Dealing Rules for Directors and Senior Executives Summary The Board encourages director and senior executives (collectively Key Management Personnel (KMP s)) to own shares in the Company

More information

Share Trading Procedure

Share Trading Procedure Share Trading Procedure This Procedure is global in application and mandatory in application for all employees and contractors working for Oil Search. 1. Objective Oil Search Limited ( Oil Search or the

More information

ABN 40 005 482 824 OZ MINERALS POLICY. Securities Trading Policy

ABN 40 005 482 824 OZ MINERALS POLICY. Securities Trading Policy ABN 40 005 482 824 OZ MINERALS POLICY Securities Trading Policy Updated by the Board with effect from 11 February 2014 1 . Securities Trading Policy 1. PURPOSE This policy outlines the law relating to

More information

Share Trading Policy. Verified by: Co Sec Corporate Governance - Policy - 003 Version Date Review Page No

Share Trading Policy. Verified by: Co Sec Corporate Governance - Policy - 003 Version Date Review Page No Share Trading Policy Initial: Share Trading 6.0 Oct 2015 Oct 2017 Page 1 Contents 1 Reasons for having a policy 3 2 Who does this Policy apply to? 3 3 Insider trading laws 3 4 The black-out period policy

More information

Securities Trading Policy Billabong International Limited

Securities Trading Policy Billabong International Limited Securities Trading Policy Billabong International Limited This is an important document. If you do not understand any aspect of this policy, it is strongly recommended that you contact the Company Secretary.

More information

Amended Security Trading Policy

Amended Security Trading Policy ASX Company Announcement Date of Release: 24 April 2015 Amended Security Trading Policy Attached is the amended Security Trading Policy of Managed Accounts Holdings Limited (MGP), approved by the MGP board

More information

Policy for Trading In Company Securities

Policy for Trading In Company Securities Policy for Trading In Company Securities Dated: 23 December 2010 SILVER LAKE RESOURCES LTD ("COMPANY") Key Management Personnel 1 who wish to trade in Company securities must first have regard to the statutory

More information

Securities Trading Policy Petrel Energy Limited

Securities Trading Policy Petrel Energy Limited Securities Trading Policy Petrel Energy Limited ACN 82 125 394 667 1 Introduction This policy deals with the sale and purchase of securities in Petrel Energy Limited ( PRL or Company ) by its employees,

More information

REVISED SECURITIES TRADING POLICY

REVISED SECURITIES TRADING POLICY 1 June 2015 REVISED SECURITIES TRADING POLICY In accordance with ASX Listing Rule 12.10, Echo Entertainment Group Limited (Echo) advises that it has amended its Securities Trading Policy. The revised policy

More information

22 nd December 2010. Australian Securities Exchange Limited Exchange Plaza 2 The Esplanade PERTH 6000

22 nd December 2010. Australian Securities Exchange Limited Exchange Plaza 2 The Esplanade PERTH 6000 22 nd December 2010 Australian Securities Exchange Limited Exchange Plaza 2 The Esplanade PERTH 6000 Chalice Gold Mines Limited - Share Trading Policy Please find attached a copy of the Chalice Gold Mines

More information

IOOF Group Securities Trading Policy

IOOF Group Securities Trading Policy IOOF Group Securities Trading Policy Reviewed and updated March 2015 Table of Contents 1. Overview 3 2. Part A: Personal Trading Guidelines for IOOF Securities 4 2.1 Scope of Part A 4 2.2 Insider Trading

More information

Australian Education Trust

Australian Education Trust Australian Education Trust ASX ANNOUNCEMENT 24 May 2013 FOLKESTONE LIMITED UPDATED SHARE TRADING POLICY Folkestone Limited (ASX:FLK) has recently completed a review of its Share Trading Policy which covers

More information

In this policy: AASB124 means the Australian Accounting Standards Board 124 December 2012 including its subsequent replacements.

In this policy: AASB124 means the Australian Accounting Standards Board 124 December 2012 including its subsequent replacements. 1 Definitions In this policy: AASB124 means the Australian Accounting Standards Board 124 December 2012 including its subsequent replacements. ASX Board Chair Company Secretary Corporations Act Director

More information

Securities Trading Policy

Securities Trading Policy Securities Trading Policy Growthpoint Properties Australia Limited for itself and as responsible entity of the Growthpoint Properties Australia Trust Adopted by the Board of directors Growthpoint Properties

More information

Securities trading policy

Securities trading policy Securities trading policy Corporate Travel Management Limited ACN 131 207 611 Level 11 Central Plaza Two 66 Eagle Street Brisbane QLD 4000 GPO Box 1855 Brisbane QLD 4001 Australia ABN 42 721 345 951 Telephone

More information

Securities Trading Policy and Guidelines for Employees and Dedicated Contractors

Securities Trading Policy and Guidelines for Employees and Dedicated Contractors (Approved by Board - April 2016) Securities Trading Policy and Guidelines for Employees and Dedicated Contractors This policy applies to all employees and dedicated contractors of New Zealand Oil & Gas

More information

Securities Trading Policy Billabong International Limited

Securities Trading Policy Billabong International Limited Securities Trading Policy Billabong International Limited This is an important document. If you do not understand any aspect of this policy, it is strongly recommended that you contact the Company Secretary.

More information

SECURITY TRADING POLICY

SECURITY TRADING POLICY SECURITY TRADING POLICY 1. INTRODUCTION This document sets out the Company s policy on the sale and purchase of its securities by its Directors, key management personnel, employees and contractors. The

More information

Share Trading Policy. IPH Limited ACN 169 015 838. Share Trading Policy 20150914

Share Trading Policy. IPH Limited ACN 169 015 838. Share Trading Policy 20150914 Share Trading Policy IPH Limited ACN 169 015 838 Share Trading Policy 1. Policy The Board has established the following policy to apply to trading in the Company s shares on ASX. The Share Trading Policy

More information

Share Trading Policy. China Dairy Corporation Limited ARBN 607 996 449. Hong Kong Registration Number 2190508. Ref GWH:US:545281. Doc ID 292441753/v2

Share Trading Policy. China Dairy Corporation Limited ARBN 607 996 449. Hong Kong Registration Number 2190508. Ref GWH:US:545281. Doc ID 292441753/v2 Share Trading Policy China Dairy Corporation Limited ARBN 607 996 449 Hong Kong Registration Number 2190508 Ref GWH:US:545281 Level 14, Australia Square, 264-278 George Street, Sydney NSW 2000 Australia

More information

SECURITIES TRADING POLICY. SRG Limited (Company) ACN 006 413 574

SECURITIES TRADING POLICY. SRG Limited (Company) ACN 006 413 574 SECURITIES TRADING POLICY SRG Limited (Company) ACN 006 413 574 Table of contents 1 Securities Trading Policy 3 Guiding Principles... 3 Purpose & Application... 3 General Trading Restriction... 4 Inside

More information

Trading In Securities Policy

Trading In Securities Policy Trading In Securities Policy Approved Date: 28th May 2015 POLICY STATEMENT This policy relates to dealings in securities and other financial products, including Meridian shares and other companies shares.

More information

Policy applies from: 1 January 2011. 1. POLICY PURPOSE: The rationale for the Policy is to ensure that Ramsay Health Care (RHC or the

Policy applies from: 1 January 2011. 1. POLICY PURPOSE: The rationale for the Policy is to ensure that Ramsay Health Care (RHC or the Policy applies from: 1 January 2011 POLICY TITLE: Securities Trading Policy 1. POLICY PURPOSE: The rationale for the Policy is to ensure that Ramsay Health Care (RHC or the Company) employees are aware

More information

For personal use only

For personal use only 1 APPENDIX E: SHARE TRADING POLICY This Share Trading Policy is for the Directors, Officers and Employees of EBOS Group Limited (EBOS) and its subsidiaries for trades in EBOS securities. The Policy is

More information

17 August 2015. Company Announcements Australian Securities Exchange Limited Level 4, 20 Bridge Street SYDNEY NSW 2000 AUSTRALIA.

17 August 2015. Company Announcements Australian Securities Exchange Limited Level 4, 20 Bridge Street SYDNEY NSW 2000 AUSTRALIA. 17 August 2015 Company Announcements Australian Securities Exchange Limited Level 4, 20 Bridge Street SYDNEY NSW 2000 AUSTRALIA Dear Sir / Madam RE: Amended Share Trading Policy In accordance with ASX

More information

POLICY ON SECURITIES TRADING BY DIRECTORS, OFFICERS, SENIOR EXECUTIVES AND OTHER EMPLOYEES 2. WHOM DOES THE SECURITIES TRADING POLICY APPLY TO?

POLICY ON SECURITIES TRADING BY DIRECTORS, OFFICERS, SENIOR EXECUTIVES AND OTHER EMPLOYEES 2. WHOM DOES THE SECURITIES TRADING POLICY APPLY TO? POLICY ON SECURITIES TRADING BY DIRECTORS, OFFICERS, SENIOR EXECUTIVES AND OTHER EMPLOYEES 1. PURPOSE The Board of Directors ( Board ) is responsible for upholding Pacific Star Network Limited s and the

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

1. INTRODUCTION 2. INSIDER TRADING IS PROHIBITED

1. INTRODUCTION 2. INSIDER TRADING IS PROHIBITED S&G SHARE TRADING POLICY 1. INTRODUCTION... 2 1.1. Purpose... 2 1.2. Who must comply with this Policy?... 2 1.3. What are the consequences of breaching this Policy?... 2 1.4. Other Restrictions on Dealings

More information

Share Trading Policy. (Group)

Share Trading Policy. (Group) Share Trading Policy (Group) Share Trading page 2 1. Introduction This policy applies to all directors and staff members of Praemium Limited (ASX:PPS) and each of its incorporated subsidiaries ( the Company

More information

Securities Dealing Policy

Securities Dealing Policy Annexure C Securities Dealing Policy Scope and Purpose The Securities Dealing Policy ( Policy ) of Advanced Surgical Design & Manufacture Limited ( ASDM ) regulates Dealings by Employees in Securities.

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

WDS LIMITED WDS PERSONNEL SHARE TRADING POLICY

WDS LIMITED WDS PERSONNEL SHARE TRADING POLICY WDS LIMITED WDS PERSONNEL SHARE TRADING POLICY 1. INTRODUCTION The Corporations Act contains provisions which prohibit a person in possession of material, non-public information relating to a company from

More information

ASX RELEASE 20 August 2015

ASX RELEASE 20 August 2015 ASX RELEASE 20 August 2015 SECURITIES TRADING POLICY In accordance with ASX Listing Rule 12.10, attached is an updated Woolworths Limited (ASX:WOW) Securities Trading Policy. WOOLWORTHS LIMITED Securities

More information

AWE LIMITED ABN 70 077 897 440

AWE LIMITED ABN 70 077 897 440 AWE LIMITED ABN 70 077 897 440 SECURITIES TRADING POLICY 1. Background Trading in the shares and other securities such as options of AWE Limited ( AWE ) is subject to, amongst other things, the Corporations

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

REVISED SHARE TRADING POLICY (ASX CODE: CND)

REVISED SHARE TRADING POLICY (ASX CODE: CND) 29 May 2012 REVISED SHARE TRADING POLICY (ASX CODE: CND) As part of a regular review of governance documentation, the Group s Share Trading Policy has been amended and is attached. By Order of the Board

More information

Namoi Cotton Co-operative Ltd Capital Stock Trading Policy Effective 24 th August 2010

Namoi Cotton Co-operative Ltd Capital Stock Trading Policy Effective 24 th August 2010 Namoi Cotton Co-operative Ltd Effective 24 th August 2010 1 PURPOSE The purpose of this Namoi is to set out Namoi Cotton s policy for trading and dealing with Namoi Capital Stock (being the Capital Co-operative

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

Share Trading Policy

Share Trading Policy Share Trading Policy 1. Introduction ROC is committed to best practice corporate governance in relation to the buying and selling of its own shares. This requires that ROC actively promote ethical and

More information

In accordance with Listing Rule 12.10, DuluxGroup Limited attaches its updated share trading policy.

In accordance with Listing Rule 12.10, DuluxGroup Limited attaches its updated share trading policy. ACN 133 404 065 1956 Dandenong Road Clayton Victoria 3168 Australia Tel: 61 3 9263 5678 16 October 2015 ASX Market Announcements Office 20 Bridge Street SYDNEY NSW 2000 SHARE TRADING POLICY In accordance

More information

In accordance with ASX Listing Rule 12.10, Fortescue Metals Group Limited (the Company) advises that it has amended its Securities Trading Policy.

In accordance with ASX Listing Rule 12.10, Fortescue Metals Group Limited (the Company) advises that it has amended its Securities Trading Policy. 20 August 2015 The Companies Officer ASX Limited 2 The Esplanade Perth WA 6000 Dear Sir, REVISED SECURITIES TRADING POLICY In accordance with ASX Listing Rule 12.10, Fortescue Metals Group Limited (the

More information

Share Trading Policy: a guide for buying and selling Bulletproof shares

Share Trading Policy: a guide for buying and selling Bulletproof shares Corporate Governance Statements 31 January 2014 Share Trading Policy: a guide for buying and selling Bulletproof shares All staff must comply with the prohibition on insider trading : never buy or sell

More information

The Company has determined that it s Key Management Personnel, for the purposes of these guidelines, are defined as:

The Company has determined that it s Key Management Personnel, for the purposes of these guidelines, are defined as: SECURITY TRADING POLICY 1. INTRODUCTION This policy relates to the sale and purchase of the Company s securities by its Key Management Personnel and procedures to reduce the risk of insider trading. Key

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

SHARE TRADING POLICY

SHARE TRADING POLICY SHARE TRADING POLICY 24 th June 2015 1. Introduction Fatfish Internet Group Limited (Fatfish) is committed to best practice corporate governance in relation to the buying and selling of its own shares.

More information