Trading Policy. W:\Policies and Procedures\Corporate\Share Trading Policy - Final.doc
|
|
- Isaac Reeves
- 8 years ago
- Views:
Transcription
1 Trading Policy Mawson West Ltd Level 1, 1 Walker Avenue West Perth, WA 6005 Telephone: (61 8) Facsimile: (61 8)
2 Summary of the Trading Policy The Trading Policy (the Policy ) exists to advise all directors, officers, employees and contractors (collectively the Representatives ) of Mawson West Ltd and its controlled subsidiaries (collectively the Company ), of their responsibilities regarding price sensitive information and insider trading. The law regulates the use and disclosure of information concerning the Company s business and activities that could affect the price of the Company s securities ( price sensitive information, also known as material information under Canadian securities laws). If Representatives or others have access to price sensitive information which has not been disclosed to the market and misuse it by trading or passing it on to unauthorised people, serious penalties may apply. A person or entity who becomes an insider (as defined in the Policy) of the Company must file an insider report on the System for Electronic Disclosure by Insiders in Canada within 10 days of the date of becoming an insider and 5 days of any change of the insider s status. In addition, Directors, officers and employees and those people who are deemed to have a special relationship with the Company are at all times prohibited from dealing in the Company s securities during the prescribed blackout periods. The blackout period timeframes are outlined in the Policy. From time-to-time, the Company Secretary will notify relevant individuals of the commencement and conclusion of unscheduled blackout periods. Additional Restrictions are placed on Restricted Employees being, directors, officers, senior executives and other persons as determined by the Chairman and the Company Secretary from time to time. Restricted Employees must apply for written acknowledgement to gain authority to subscribe for, purchase or sell, or enter into an agreement to subscribe for, purchase or sell, any securities (ie. shares or options) in the Company. Further Information Representatives may not, disclose information to anyone outside the Company, including family members and friends, other than in accordance with Company procedure. Before engaging in any transaction, it should be carefully considered how enforcement authorities and others might view the transaction in hindsight. As a general rule, information should not be considered fully absorbed by the marketplace until the next trading day after the information is released. The Policy also applies to anyone who lives in the household of the Representative and any family members whose transactions in Company securities are directed/influenced by the Representative. Restricted Employees may not engage in any of the following transactions: o Short Term Trading; and o Short Sales. Any person who has a question about this Policy or its application to any proposed transaction may obtain additional guidance from the Company Secretary. Ultimately, responsibility for adhering to this Policy and avoiding unlawful transactions rests with the individual. Please be aware this summary does not replace the requirement for Representatives to read the Policy in its entirety. 2
3 Contents Summary of the Trading Policy... 2 Contents... 3 Section 1 Statement of Purpose... 4 Section 2 Overview... 4 Price Sensitive Information... 5 Relevant Legislation... 5 Section 3 Application of the Policy... 7 Insider Reporting Obligations... 7 Protocol for Dealing in Company Securities... 7 Section 4 Further Information
4 Section 1 Statement of Purpose This Trading Policy (the Policy ) exists to advise all Directors, officers, employees and contractors (collectively the Representatives ) of Mawson West Ltd and its controlled subsidiaries (collectively the Company ), of their responsibilities regarding continuous disclosure, price sensitive information, and insider trading. The Company takes insider trading very seriously and it expects its Representatives to do the same. This document outlines the Company s policy and procedures for compliance with the laws concerning insider trading, and is intended to protect Representatives from inadvertently breaching those rules. All Representatives of the Company are subject to this Policy relating to trading in the Company s securities and where relevant, securities of other public issuers. Compliance with insider trading laws and this Policy is an individual s responsibility and any breach will be regarded by the Company as serious misconduct which may lead to disciplinary action and/or dismissal. Section 2 Overview Mawson West Ltd is an Australian company with shares that are publicly traded and presently listed on the Toronto Stock Exchange ( TSX ). As such, the law regulates the use and disclosure of information concerning the Company s business and activities that could affect the price of the Company s securities ( price sensitive information, also known as material information under Canadian securities laws). The laws on insider trading exist to prevent people who have price sensitive information that is not known to the market (insiders) from taking advantage of it. If Representatives or others have access to price sensitive information which has not been disclosed to the market and misuse it by trading or passing it on to unauthorised people, serious penalties may apply. Compliance with this Policy does not necessarily equate to compliance with applicable legislation. If you have any questions or if you are unsure whether any particular information is material or price sensitive or whether it has been disclosed to the public as required, you are encouraged to contact the Company Secretary at: Caroline Keats Company Secretary Mawson West Ltd Level 1, 1 Walker Avenue West Perth, Western Australia 6005 Phone: Fax:
5 Price Sensitive Information Price sensitive information is, generally described as, non-public information that would reasonably be expected to have a material (or significant) effect on the price or value of the Company s securities. Hereafter are only a few examples of price sensitive information include: A material change in the Company s financial forecast, expectation or position; A material change in the Company s ore resources or reserves forecast or expectation; Projections of future earnings, losses, cash flows or other key financial performance measure; Significant mineral discoveries or exploration results; The existence of key projects to acquire additional interests; The existence of key projects to dispose of the Company s businesses or assets; Intended debt or equity financings by the Company; The impending appointment or departure of a key senior executive or Director; An impending changes in share ownership that may affect control of the Company; The intention to declare a dividend or change dividend policy; and The gain or loss of a significant customer or supplier. As a starting point you should regard all information about the Company and its business and activities as confidential and price sensitive, unless you are certain that the information is in the public domain or is not otherwise sensitive or restricted. Should you have any doubt regarding the nature of such information, you are encouraged to contact the Company Secretary. Relevant Legislation As a Representative of the Company, you may from time to time obtain or have access to price sensitive information that is not generally available to others outside of the Company. That information is inside information and as a recipient of that information you will be restricted in your ability to use and disclose that information until it has been made generally available to the public. In particular, securities legislation prohibits any person who is an insider, or who is in a special relationship with the Company, from either: Purchasing or selling the Company s shares with the knowledge of price sensitive information concerning the Company that has not been generally disclosed; or 5
6 Informing (or tipping ), other than when necessary in the course of business, another person or company of price sensitive information concerning the Company before the sensitive information has been generally disclosed. The definition of an insider varies from statute to statute but in any case will include directors and senior officers of the Company. Generally, securities legislation defines insiders as: Every director or senior officer of a public issuer; Every director or senior officer of an issuer that is itself an insider of a public issuer; Any person or entity that: o Exercises control or direction over voting securities of a public issuer, or o Beneficially owns, directly or indirectly, certain voting securities of a public issuer and exercises control or direction over certain other voting securities of a public issuer, carrying more than 10% of the voting rights attached to all voting securities of the public issuer for the time being outstanding other than voting securities held by the person or Company as underwriter in the course of distribution. A senior officer includes, the Chief Executive Officer, the Chief Operating Officer, the Chief Financial Officer, senior executives, the Secretary, the Treasurer, the Financial Controller or any other individual who performs functions for an issuer similar to those normally performed by an individual occupying any such office. Those people deemed to have a special relationship with the Company are as follows: Any person or entity that is an insider, affiliate or associate of the Company; Any person employed or retained by the Company; Any person having privileged information in the course of his or her relations with the Company; Any person having privileged information that was disclosed by an insider or by any of the foregoing persons; or Any person who has acquired privileged information that he or she knows to be such. The penalties for a breach of prohibitions are onerous. In both Canada and Australia, a breach may render an offender personally liable to prosecution and, upon conviction, to a fine, a jail sentence, or both. In addition, an offender may be subject to civil actions initiated by certain security holders, the companies whose securities were traded, and various securities commissions. If you are unsure whether or not you may trade in a given circumstance, you should contact the Company Secretary to determine whether or not the particular information is material. 6
7 Section 3 Application of the Policy The application of this Policy is directed to ensuring that Representatives meet their insider reporting and trading obligations. Central to fulfilling these obligations is adherence to the protocol for dealing in the Company s securities. Insider Reporting Obligations A person or entity who becomes an insider of the Company must file an insider report on the System for Electronic Disclosure by Insiders ( SEDI ) in Canada within ten days of the date of becoming an insider, reporting their status as an insider and the securities of the Company over which they have direct or indirect beneficial ownership or control or direction. With prior arrangement, assistance in filing the insider report can be provided by the Company Secretary. However, the obligation to report still falls on the insider. An insider whose direct or indirect beneficial ownership of or control or direction over securities of the Company subsequently changes, (including a grant, exercise or expiry of stock options) must file on SEDI, an insider report of the change within five days of the date of the change. Insiders may choose to delegate their SEDI reporting obligations to the Company Secretary or undertake such reporting independently. Those individuals that delegate regulatory reporting to the Company Secretary must provide to the Company Secretary, all details of any transaction to which the SEDI reporting obligations apply, within 72 hours of the transaction taking place. Protocol for Dealing in Company Securities Prescribed Blackout Periods In addition to the overriding prohibition against dealing in the Company s securities when a person is in possession of price sensisitve information, Directors, officers and employees are at all times prohibited from dealing in the Company s securities during the prescribed blackout periods. For the first, second and third quarters, the blackout period is the ten days immediately preceding the results announcements and terminating the next trading day after the release date of the quarter s results, unless otherwise advised by the Company. For the December 31 year-end financial statements, the blackout period extends from February 1 and terminates the next trading day following the release of year end results, unless otherwise advised by the Company. Notice of commencement and cessation of black out periods will be circulated once determined. The blackout periods may be varied by the Board of Directors and circulated, with appropriate notice, to all Directors, officers and employees. 7
8 Unscheduled Developments In addition to the prescribed blackout periods noted above and the overriding prohibition against dealing in the Company s securities when a person is in possession of price sensitive information, blackout periods may arise as a result of unscheduled developments. Unscheduled developments include significant corporate acquisitions, divestitures, contract negotiations, material new information regarding the Company s resources or reserves, asset write downs, or similar transactions that will generally result in a material change in the affairs of the Company. From time-to-time, the Company Secretary will notify relevant individuals of the commencement and conclusion of blackout periods resulting from such unscheduled developments. Restricted Employees Additional restrictions are placed on trading by directors, officers, senior executives and other persons as determined by the Chairman and Company Secretary from time to time. These will be known as Restricted Employees. The Company Secretary maintains a list of Restricted Employees. Written Acknowledgement All Restricted Employees must apply for written acknowledgement (see application form at Annexure A which also states those authorised to give written acknowledgement), to gain authority to, whether in their own capacity or as an agent for another, subscribe for, purchase or sell, or enter into an agreement to subscribe for, purchase or sell, any securities (ie. shares or options) in the Company. Section 4 Further Information The following notes are provided as additional information to help clarify certain aspects related to insider trading. a) Disclosure of Information to Others. The Company has established procedures for releasing material information in a manner that is designed to achieve broad public dissemination of the information immediately upon its release. You may not, therefore, disclose such information to anyone outside the Company, including family members and friends. You also may not discuss the Company or its business in an internet chat room or similar internet-based forum. The requirements of this Policy are in addition to existing policies and agreements with respect to the non-disclosure of confidential information and the general rule that the Company s business is not to be discussed with anyone outside the Company except as necessary in connection with the conduct of the Company s business. As a director, officer, employee or contractor of a company whose shares are actively traded on the TSX, you should be aware that many people, including stock brokers, market analysts, journalists and stockholders have an interest in information about the Company and may seek to obtain it from you. If you receive any inquiry of this kind, you should decline to respond and refer the inquiry to the Company Secretary. 8
9 b) Twenty-Twenty Hindsight Anyone scrutinizing transactions will be doing so after the fact, with the benefit of hindsight. As a practical matter, before engaging in any transaction, carefully consider how enforcement authorities and others might view the transaction in hindsight. c) When Information is Public If you are aware of material non-public information, you may not trade until the information has been disclosed broadly to the marketplace (such as by press release or a SEDAR filing) and the investing public has had time to absorb the information fully. To avoid the appearance of impropriety, as a general rule, information should not be considered fully absorbed by the marketplace until the next trading day after the information is released. If, for example, the Company was to make an announcement on a Monday, you should not trade in the Company s securities until Tuesday. If an announcement was made on a Friday, Monday generally would be the first eligible trading day. Holidays in which securities markets are closed are not business days and therefore extend the applicable period. d) Transactions by Family Members and Other Related Parties The Policy also applies to your family members who reside with you, anyone else who lives in your household, and any family members who do not live in your household but whose transactions in the Company securities are directed by you or are subject to your influence or control (such as parents or children who consult with you before they trade in the Company stock). The Policy also applies to partnerships of which you are a partner, trusts of which you are a trustee or in which you have a substantial beneficial interest, estates of which you are an executor and investment funds or similar vehicles with which you are affiliated. You are responsible for the transactions of these other persons and therefore should make them aware of the need to confer with you before they trade in the Company s stock. e) Stock Option Exercises The Policy does not apply to the exercise of an employee stock option unless otherwise directed by the Company Secretary. The Policy does apply, however, to any sale of the Company s securities acquired on exercise of stock options, including sales as part of a broker assisted cashless exercise of an option, or any other market sale for the purpose of generating the cash needed to pay the exercise price of an option. f) Additional Prohibited Transactions. The Company considers it improper and inappropriate for any Restricted Employee of the Company to engage in short-term or speculative transactions in the Company s securities. It therefore is the Company s policy that Restricted Employees may not engage in any of the following transactions: 9
10 Short-term Trading Short-term trading of the Company s securities may be distracting to the employee and may unduly focus the employee on the Company s short-term stock market performance instead of the Company s long-term business objectives. For these reasons, any Restricted Employee of the Company who purchases the Company s securities in the open market may not sell any Company securities of the same class during the six months following the purchase. A Restricted Employee, other than a director or officer, may apply for a hardship exemption from this prohibition, but in the absence of a significant and unforeseen problem, such a request will be ordinarily denied. Short Sales Short sales of the Company s securities evidence an expectation on the part of the seller that the securities will decline in value, and therefore signal to the market that the seller has no confidence in the Company or its short-term prospects. In addition, short sales may reduce the seller s incentive to improve the Company s performance. For these reasons, this Policy prohibits short sales of the Company s securities. Exercising employee options and then selling the shares does not constitute a short sale. g) Post-Termination Transactions This Policy continues to apply to your transactions in the Company securities even after you have terminated employment. If you are in possession of material non-public information when your employment terminates, you may not trade in Company securities until that information has become public or is no longer material. You are reminded that the prohibition under securities laws on trading while in possession of material non-public information applies to anyone and is not limited to employees of the issuer. Accordingly, the risk of a violation and the imposition of penalties as outlined above does not end when you terminate your employment with the Company. Any person who has a question about this Policy or its application to any proposed transaction may obtain additional guidance from the Company Secretary. Ultimately, however, the responsibility for adhering to this Policy and avoiding unlawful transactions rests with the individual. 10
11 ANNEXURE A APPLICATION FOR WRITTEN ACKNOWLEDGEMENT PRIOR TO DEALING IN THE SECURITIES OF MAWSON WEST LTD Name:.. (BLOCK CAPITALS PLEASE) Securities as indicated below: NUMBER AND CLASS OF SECURITIES (eg: ordinary shares) REGISTERED IN THE NAME OF (see Note 1) NATURE OF INTEREST (see Note 2) NATURE OF TRANSACTION (see Note 3) As far as I am aware, I am not in possession of any unpublished price-sensitive information in relation to Mawson West Ltd, its subsidiaries and related companies. If this should change before the deal is transacted I undertake not to proceed. Please provide acknowledgement by counter-signing and returning a duplicate of this form. Signed:. Date:. Name:.. Title: Permission given on the basis that the transaction is completed by no later than 7 business days of clearance being received. Signed: Date:.. (Please see overleaf for signing authorities) Notes: (1) REGISTERED IN THE NAME OF Give full name and if not yourself state the connection to yourself (2) NATURE OF INTEREST Specify precisely, ie: personally, joint holding or as trustee (3) NATURE OF TRANSACTION Specify precisely, eg: sale of shares 11
12 Authorisation levels In the case of an employee or his or her associate, the Company Secretary, CEO or Chairman In the case of an officer or his or her associate, the Company Secretary, CEO or Chairman In the case of a director or his or her associate, the Chairman In the case of the Chairman or his or her associate, the Chairman of the Audit Committe 12
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 informationQUESTERRE 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 informationALMONTY 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 informationALARIS ROYALTY CORP. TRADING AND BLACKOUT POLICY
ALARIS ROYALTY CORP. TRADING AND BLACKOUT POLICY Purpose The purpose of this Policy is to ensure compliance with applicable Canadian securities laws governing trading in securities of Alaris Royalty Corp.
More informationLion One Metals Ltd. Insider Trading Policy
Lion One Metals Ltd. Insider Trading Policy 1.0 Introduction The Board of Directors of Lion One Metals Ltd. ( Lion One ) 1 has determined that Lion One should formalize its policy on securities trading
More informationSEAFIELD 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 informationPolicy Title: INSIDER TRADING POLICY # of Pages - 10. Approval Source: Board of Directors
GIBSON ENERGY (and affiliated companies) POLICY Department Responsible: Legal Policy # CORP 6.0 Policy Title: INSIDER TRADING POLICY # of Pages - 10 Initial Approval Date: August 10, 2011 Revision #: 2
More informationInca One Gold Corp. Insider Trading Policy
Inca One Gold Corp. Insider Trading Policy 1.0 Introduction The Board of Directors (the Board ) of Inca One Gold Corp. ( Inca One ) 1 has determined that Inca One should formalize its policy on securities
More informationINSIDER TRADING POLICY
INSIDER TRADING POLICY General The purchase or sale of Midway Gold Corp s (the Company ) securities while aware of material nonpublic information, or the disclosure of material nonpublic information to
More informationGB 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 informationCPI CARD GROUP INC. INSIDER TRADING POLICY
CPI CARD GROUP INC. INSIDER TRADING POLICY CPI Card Group Inc. (the Company ) and its Board of Directors have adopted this Insider Trading Policy (this Policy ) both to satisfy our obligation to prevent
More informationINSIDER 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 informationSECURITIES TRADING AND INVESTMENT POLICY
STEWART INFORMATION SERVICES CORPORATION SECURITIES TRADING AND INVESTMENT POLICY I. PURPOSE AND SCOPE This Policy is intended to provide guidance to all Company Employees of Stewart Information Services
More informationINSIDER 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 informationCIVITAS 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 informationINSIDER TRADING AND BLACKOUT POLICY
HUMAN RESOURCES POLICY Policy Number RH-GEN.10 Date issued 2005-09-08 Date updated Approved at July 30, 2014 meeting of the Board of Directors Issued by Human Resources Department Approved by Management
More informationEXHIBIT F POLICY ON INSIDER TRADING. ewellness HEALTHCARE CORPORATION THE BASICS
POLICY ON INSIDER TRADING ewellness HEALTHCARE CORPORATION Company insiders are subject to individual responsibilities and restrictions in addition to the responsibilities and obligations of the company
More informationInsider Trading Policy
Insider Trading Policy FEBRUARY 2014 Table of Contents 1. Introduction... 2 2. Insider Trading Restrictions... 2 a) Insider Trading Restrictions... 2 b) Material Information... 3 c) Persons in Special
More informationTRIMETALS MINING INC. SHARE TRADING POLICY (As at March 7, 2011)
TRIMETALS MINING INC. SHARE TRADING POLICY (As at March 7, 2011) I. Purpose Applicable securities laws in Canada prohibit the purchase or sale of securities on the basis of material non-public information
More informationPHOENIX 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 informationINSIDER 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 informationINSIDER TRADING AND REPORTING POLICY
INSIDER TRADING AND REPORTING POLICY I. INTRODUCTION Employees, officers, directors, consultants, contractors and agents of Pembina Pipeline Corporation (the "Corporation") and its subsidiaries may from
More informationInsider 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 informationSecurities 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 informationSECURITIES 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 informationINSIDER 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 informationIOOF 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 informationINSIDER TRADING POLICY SUPERIOR PLUS CORP.
INSIDER TRADING POLICY SUPERIOR PLUS CORP. A fundamental principle of securities legislation is that everyone investing in securities should have equal access to information that may affect their decision
More informationSecurities 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 informationINPHI CORPORATION. Insider Trading Policy and Communication Policy. As Amended July 25, 2014
INPHI CORPORATION Insider Trading Policy and Communication Policy As Amended July 25, 2014 1. INTRODUCTION Both the Securities and Exchange Commission (the SEC ) and Congress are very concerned about maintaining
More informationM 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 informationGEOGRAPHIC COVERAGE: DATE REVISED: May 2015 1. GENERAL
FORM / POLICY TITLE: GEOGRAPHIC COVERAGE: DOCUMENT OWNER: Insider Trading Policy Global SVP & General Counsel DATE REVISED: May 2015 1. GENERAL Generally there are laws in each jurisdiction in which Gartner
More informationSECURITIES 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 informationINSIDER TRADING POLICY
INSIDER TRADING POLICY Introduction To protect investors and promote confidence in the trading of shares and other securities of public companies, securities legislation applicable in Canada prohibits
More informationNOVAGOLD RESOURCES INC. (THE COMPANY ) INSIDER TRADING POLICY
PURPOSE NOVAGOLD RESOURCES INC. (THE COMPANY ) INSIDER TRADING POLICY The Company is a publicly traded company listed on the Toronto Stock Exchange (the TSX ) and the NYSE MKT LLC (the NYSE MKT, and together
More informationUSA Truck, Inc. Insider Trading Policy July 29, 2015
USA Truck, Inc. Insider Trading Policy July 29, 2015 I. Purpose. The purpose of this Insider Trading Policy (this "Policy") is to promote compliance with applicable securities laws by USA Truck, Inc. (the
More informationTHE HERSHEY COMPANY INSIDER TRADING POLICY
THE HERSHEY COMPANY INSIDER TRADING POLICY I. PURPOSE The Hershey Company (the Company ) has adopted this Insider Trading Policy (this Policy ) to help its directors, officers and employees comply with
More informationPURPOSE 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 informationSHARE 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 informationNETFLIX, 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 informationCORPORATE DISCLOSURE AND SECURITIES TRADING POLICY
1.0 INTRODUCTION An underlying principle of securities legislation is that the public should have the opportunity to decide whether to buy or sell securities on the basis of information equally available
More informationTARTISAN RESOURCES CORP. INSIDER TRADING AND BLACK-OUT POLICY
TARTISAN RESOURCES CORP. INSIDER TRADING AND BLACK-OUT POLICY DECEMBER 21, 2010 Table of Contents EXECUTIVE SUMMARY... 3 INTRODUCTION... 3 MATERIAL INFORMATION... 4 PERSONS IN A SPECIAL RELATIONSHIP WITH
More informationInsider 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 information22 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 informationINSIDER 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 informationThis Policy is not intended to replace your individual responsibility to understand and comply with the legal prohibitions against insider trading.
INSIDER TRADING POLICY DOCUMENT REFERENCE REVISION NUMBER TOTAL PAGES ORIGINAL ISSUE DATE EFFECTIVE DATE 3 11 October 25, 1995 November 11, 2014 SCOPE: This Policy is applicable to every employee of Barrick
More informationVISTA GOLD CORP. INSIDER TRADING POLICY
VISTA GOLD CORP. INSIDER TRADING POLICY (Adopted on December 19, 2003, as amended on March 2, 2009 and March 5, 2013) 1. BACKGROUND AND PURPOSE The federal securities laws of the United States and applicable
More informationPROPHASE LABS, INC. POLICY STATEMENT SECURITIES TRADES BY COMPANY PERSONNEL
PROPHASE LABS, INC. POLICY STATEMENT SECURITIES TRADES BY COMPANY PERSONNEL The Need For A Policy Statement Federal securities laws make it illegal for you-- the directors, officers and Associates of ProPhase
More informationPOLICY GUIDANCE & STANDARDS
Current versions of approved documents are maintained online. Printed copies are uncontrolled. Page 1 of 5 POLICY GUIDANCE & STANDARDS TRADING BLACKOUTS FOR RESTRICTED PERSONS Number : CO-059 Date Developed:
More informationINSIDER TRADING POLICY. Guidelines with Respect to Certain Transactions in Company Securities
INSIDER TRADING POLICY Guidelines with Respect to Certain Transactions in Company Securities This Policy provides guidelines to all employees, officers and directors of F5 Networks, Inc. and its subsidiaries
More informationSecurity 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 informationSecurities 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 informationPURPOSE Scope of Policy
PURPOSE Nicolet Bankshares, Inc. s board of directors has adopted this Insider Trading Policy (the Policy ) for our directors, officers, employees and consultants (collectively, Covered Persons ) with
More informationINSIDER TRADING AND BLACKOUT PERIOD POLICY STINGRAY DIGITAL GROUP INC. APRIL 21, 2015
INSIDER TRADING AND BLACKOUT PERIOD POLICY STINGRAY DIGITAL GROUP INC. APRIL 21, 2015 1. Introduction 1.1 Expectations INSIDER TRADING AND BLACKOUT PERIOD POLICY STINGRAY DIGITAL GROUP INC. APRIL 21, 2015
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CONDUCT AND ETHICS Wellgreen Platinum Ltd. Suite 1128-1090 West Georgia Street 604.569.3690 info@wellgreenplatinum.com CODE OF BUSINESS CONDUCT AND ETHICS I. INTRODUCTION This Code of
More informationBy 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 informationprovide 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 informationJB 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 informationSecurities 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 informationTrading 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 informationInsider 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 informationIn 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 informationSHARE 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 informationREVISED 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 informationSecurities 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 informationPolicy. 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 informationCITIZENS, 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 informationShare 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 informationRestrictions on Buying and Selling Stock and Securities (Insider Trading Policy)
Restrictions on Buying and Selling Stock and Securities (Insider Trading Policy) 1. Policy Statement Employees, consultants, contractors, officers, members of the Board of Directors and entities (such
More informationThis 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 informationSecurities 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 information1 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 information2.0 LEGAL BACKGROUND; ENFORCEMENT
PENNSYLVANIA REAL ESTATE INVESTMENT TRUST PREIT SERVICES, LLC Code of Business Conduct and Ethics: Policy on Selective Disclosure of and/or Use of Inside Information 1.0 PURPOSE This Policy is intended
More informationAMP 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 informationIn 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 informationShare 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 informationShare 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 informationCANADA STRATEGIC METALS. (the Corporation ) TRADING AND BLACKOUT POLICY
CANADA STRATEGIC METALS (the Corporation ) TRADING AND BLACKOUT POLICY This Policy provides guidelines to directors, Officers (as defined below), employees and consultants of Canada Strategic Metals (
More informationBARRA 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 informationShare 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 informationHow To Comply With The Morningstar Policy
Morningstar, Inc. Securities Trading and Disclosure Policy Amended and in effect on May 12, 2015 At Morningstar, we encourage our employees to be investors. However, because the people who use our products
More informationSHARE 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 informationInsider Trading Policy
Insider Trading Policy Revised and Adopted by the Board of Directors on September 29, 2014 This Policy provides guidelines to personnel of Gilat Satellite Networks Ltd. and its subsidiaries (collectively,
More informationSecurities 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 informationShare 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 informationInsider Trading Policy
Insider Trading Policy TABLE OF CONTENTS Policy Statement... 1 Policy Questions... 1 Companies Covered... 2 Persons Covered... 2 Transactions Covered... 2 Open Market Transactions... 2 401(k) Plan... 2
More informationPERSHING GOLD CORPORATION CORPORATE POLICY AND PROCEDURE ON INSIDER TRADING. Adopted November 4, 2014
PERSHING GOLD CORPORATION CORPORATE POLICY AND PROCEDURE ON INSIDER TRADING 1. Introduction Adopted November 4, 2014 United States federal securities laws seek to ensure that all investors in the publicly
More informationPolicy Statement. Purpose. Applicability. Summary
Subject: Disclosure and Stock Trading Policy Number: L.01.01 Department Name: Law Department Page: 1 of 7 Original Issue Date: July 30, 2002 Revision Date: January 13, 2012 Policy Owner: General Counsel
More informationABM 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 informationINSIDER TRADING POLICY POLICY STATEMENT DETAIL
INSIDER TRADING POLICY POLICY STATEMENT American Electric Power Company, Inc. and certain of its subsidiaries are the issuers of securities that are registered with the Securities and Exchange Commission.
More informationINSIDER TRADING POLICY
INSIDER TRADING POLICY PURPOSE: U.S. federal securities laws prohibit the purchase and sale of securities at a time when the person possesses material, non-public information (positive or negative) concerning
More informationNEWFIELD 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 informationSecurities 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 informationC-103 External Communications Policy
CORPORATE POLICIES C-103 External Communications Policy Table of Contents 1.0 Purpose and Policy... 1 2.0 Definitions... 2 3.0 Scope and Responsibilities... 2 4.0 Disclosure Controls and Procedures...
More informationSecurities 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 informationORION ENGINEERED CARBONS S.A. INSIDER TRADING POLICY. All defined terms shall have the meanings set forth in the Annex A.
ORION ENGINEERED CARBONS S.A. INSIDER TRADING POLICY In order to take an active role in the prevention of insider trading violations by its officers, directors, employees and other individuals, Orion Engineered
More informationAll 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 informationSecurities 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 informationIt is a Criminal Offence to buy or sell the shares of any publicly listed company if you have inside information about that company.
Policy: Air New Zealand Securities Trading Department/division: Legal/Governance Version Number: 1.2 Last Updated: September 2014 The Law The following is a brief summary of the law for guidance only.
More informationSecurities 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