Lonsec Limited ABN 56 061 751 102 AFSL 246842 Market Participant of ASX Group 31-10-2013
Contents DATE PREPARED 01-11-2013 1. Introduction 3 1.1 Definitions 3 1.2 Reason for this policy 3 1.3 Relevant Lonsec policies 3 1.4 Effective date is the date appearing on the sign off/approval section found on the document management page of this policy 3 2. Scope 3 2.1 Special requirements for research analysts 4 2.2 What about Staff or Staff related personnel superannuation funds? 4 2.3 What about investment clubs and syndicates, and discretionary accounts managed by someone else? 4 2.4 Which financial products are covered? 4 2.5 Are dealings in any financial product exempt? 4 2.6 Rights or bonus issues, takeover offers and SPPs 4 2.7 Records of holdings 5 3. Market dealings on Staff & Staff-Related Accounts 5 3.1 New Staff account procedures 5 3.2 Broker/CHESS sponsorship 5 3.3 Existing HIN 5 3.4 Margin lending 5 3.5 Options trading or CFD s 5 3.6 Confirmations 5 3.7 Prior written authorisation required 5 3.8 Authorisation 6 3.9 Restricted list 6 3.10 Trading embargo release of research report 7 3.11 Short selling 7 3.12 Placing the order 7 3.13 Minimum holding period is 48 hours 7 3.14 Use of suspense accounts prohibited 7 3.15 Dealings monitored, market activity may be limited or stopped 7 4. Allocation to Staff & Staff Related Accounts 8 4.1 Allocation criteria for issues formally involving Lonsec 8 4.2 Non-public information 8 4.3 New issues not involving Lonsec 8 5. Settlement 8 5.1 Secondary market dealings 8 5.2 Primary market dealings 9 6. Reporting new Staff & Staff Related Accounts 9 7. Accounts/dealing at other firms or for Staff of other firms 9 7.1 Accounts & dealing at other firms 9 7.2 Accounts & dealing for Staff of other firms are prohibited 10 P 2-10 2013 Lonsec Fiscal Holdings Pty Ltd, ABN 41 151 235 40
DATE PREPARED 01-11-2013 1. Introduction The definitions of Staff and Staff-Related Account and related terminology are extremely important and must be common knowledge to all Staff employed by Lonsec Limited, trading as Lonsec Stockbroking (Lonsec). 1.1 Definitions Employees (Staff) includes all employees, members, representatives, authorised representatives and contractors and consultants Cleared funds means sufficient funds in the Staff member s bank account used for settlement by the date of settlement to cover the total purchase including brokerage and any other fees. Staff or Staff-Related Account is defined as an account: In the name of the Staff member (including joint accounts of which the Staff member is a party); or In the name of a Staff members: Immediate Family means your spouse or children under 18 years old of your household (i.e. living with you at your place of residence). Family Company, being a corporation controlled by you or a member(s) of your immediate family, or a corporation to which you are beneficially entitled to more than 50% of the issued capital. Family Trust, being a trust which you are or member(s) of your immediate family is the sole or majority beneficiary, or a trust where you have the ability to remove and replace the trustee with a person or entity nominated by you; or Controlled Trust, being a Trust in relation to which you, a member(s) of your Immediate Family or a corporation controlled by you: Where the Staff member is as either a trustee or a director of a corporate trustee of a DIY super fund; Where the Staff member is entitled to more than 50% of the trust s whole beneficial interest; or Where the Staff member controls the Trust. Examples and expansions of terms used in this Policy are for description only and are not exhaustive. Securities not specifically noted are also included in the controls established by this Policy. 1.2 Reason for this policy This policy is to ensure that all Staff are aware of their obligations in relation to the declaration, establishment and trading of Staff and Staff Related Accounts, and the significant impact of ASIC and ASX regulatory requirements on Staff and proprietary/house dealings. All Staff and Staff-Related Accounts must be declared during your induction, or whenever subsequently opened, and identified accordingly in Lonsec s system 1.3 Relevant Lonsec policies This policy is to be read in conjunction with: Conflicts of Interest Policy Ethical Dividers Policy; and Any other policy or procedure which forms part of Lonsec s compliance program. 1.4 Effective date is the date appearing on the sign off/approval section found on the document management page of this policy This Policy shall subject to regular review by the Lonsec Executive in conjunction with Lonsec Fiscal Holdings Pty Ltd (LFH) Group Compliance to ensure its currency with Lonsec`s statutory obligations. 2. Scope This policy applies to all members of Lonsec and all employees (Staff) of Lonsec. A reference to Staff (i.e. a Staff member) includes all full/part time and full time casual persons, whether they be director, employee, consultant, or authorised representative, or employees of an Authorised Representative operating under an AFSL of a related entity or member for as long as they are working within Lonsec s premises. P 3-10
P 4-10 DATE PREPARED 01-11-2013 Consultants or Temporary Staff under contract for greater than three months are expected to comply fully with the procedures outlined in this policy while those under contracts for less than three months are expected to comply with the spirit of this policy or as directed. The Executive, in consultation with LFH Group Compliance, has the final discretion on sub-contractors or agents. 2.1 Special requirements for research analysts Equity Research Analysts must not deal in the financial products of the issuers which they cover (and their related issuers) during the preparation of a Research Report. Research Analysts must inform the Responsible Manager/Executive or the LFH Group Compliance unit whenever they prepare a report for a company in which they hold securities to allow the correct disclosures /disclaimers to be attached. In all other respects, Analysts are subject to the requirements which apply to all Staff. Exceptions to this condition must be obtained from the executive. 2.2 What about Staff or Staff related personnel superannuation funds? This policy applies to Staff or Staff related Self-Managed Superannuation Fund or to any other complying superannuation fund where you have the ability to direct investments into specific financial products or fund managers. It does not apply to cash contributions or contributions into default options within a Staff or Staff related Self-Managed Superannuation Fund or switch in investment options within a superannuation fund, i.e. balanced, growth, income etc. 2.3 What about investment clubs and syndicates, and discretionary accounts managed by someone else? Prior to Staff forming a or participating in an investment syndicate or club they must obtain prior permission from LFH Group Compliance and advise the name of all persons comprising membership of the club. The Staff member must also advise of any changes to the club s membership, its rules or constitution thereafter and provide a document setting out the particulars to LFH Group Compliance. Lonsec will assume that each transaction is undertaken for the equal benefit of all members, if this is not the case the Staff member must advise appropriately. The account name should include Staff syndicate or investment club. The usual order authorisation procedures will apply (see Section 3) and requests must include the names of all members of the syndicate or club. Accounts held by Staff or their immediate family capable of trading securities are to be closed unless authorised under Section 7 of this policy or agreed in accordance with LFH Group Compliance and Lonsec s Exceptions to Policies procedures. Accounts held by Staff or their immediate family where another person places trading instructions must be identified and discussed with LFH Group Compliance Services. 2.4 Which financial products are covered? This section covers all products, whether foreign or Australian, which includes: Financial Products, whether equity or debt, whether issued by a corporation or other entity (e.g. unit trust, Managed Funds, MIS), and whether or not the financial products are quoted (or expected to be quoted) on an Exchange (e.g. shares, company options, instalment receipts, convertible notes, forfeited contributing shares purchased at auction). This includes Securities or other Financial Products issued by government, local authorities, public authorities or international agencies. Equity Derivatives, whether exchange listed or not (e.g. CFD s, Exchange Traded Options, Warrants), including those having an underlying Market Index in addition to those having an underlying security. Futures, including Exchange Traded Options over Futures, on currencies, interest rates, commodities, indices or equities (but not spot foreign currency transactions). Over-the-Counter Products of any nature. 2.5 Are dealings in any financial product exempt? The procedures and restrictions detailed in this Policy do not apply to Staff or Staff-Related dealings in: Bank Bills, Certificates of Deposit and similar products negotiated directly with your Bank. Cash Management Trust units (i.e. deposits and withdrawals from a Cash Management trust). Insurance products 2.6 Rights or bonus issues, takeover offers and SPP`s From time to time, as a holder of financial products, your holding may be subject to a split or consolidation, or you may become entitled to rights, bonus or other issue of financial products by the issuer or related issuer or takeover offer. In these circumstances no market dealings are involved. The acquisition of financial products by these means falls outside Sections 3 and 4 of this policy. Any market sale of an entitlement or the purchase of more to top-up will be subject to Section 3. If a top-up is facilitated directly by the issuer, then neither Sections 3 nor 4 apply to the transaction. Subsequent market dealings involving those financial products must be transacted through Lonsec.
P 5-10 DATE PREPARED 01-11-2013 2.7 Records of holdings Staff are obliged to maintain a register of holdings, including both ASX-listed Financial Products and non ASX-listed Financial Products. The Registers will be monitored and reviewed periodically, but LFH Group Compliance unit can at any time demand to see the register to ensure it conforms and meets ASIC requirements. This requirement will be met for ASX-listed Financial Products if Staff are Broker Sponsored by Lonsec, which is compulsory. For sponsored requirements (See Section 3). Staff who take up IPO/New Issues should instruct the issuer for that stock be sponsored by Lonsec. Where it is issuer sponsored, Staff must initiate sponsorship by Lonsec upon receipt of an issuer sponsored notice. Where Staff intend to hold a specific Financial Product as Issuer, the circumstances must be advised to LFH Group Compliance and recorded on the Staff member s holdings register e.g. one-off shareholding- in name of child or in different format to CHESS details. 3. Market dealings on Staff & Staff-Related Accounts All secondary market dealings by Staff and Staff-Related Accounts must be executed by Lonsec unless exception is granted and will be subject to Client Order and Allocation Precedence requirements and settlement performance obligations (See Section 5). 3.1 New Staff account procedures When a Staff member wishes to open a new Staff or Staff-related account, he or she must complete and sign-off a New Account Application Form. The completed forms should be signed and reviewed by a Responsible Managers/Executive before the new account is processed and the Compliance unit informed of the accounts establishment. 3.2 Broker/CHESS sponsorship Lonsec requires all Staff and Staff-Related Accounts to be Broker Sponsored by Lonsec Limited. Any exceptions to this requirement must be approved by the Executive and advised to LFH Group Compliance. Being Broker Sponsored by Lonsec enables us to identify your holdings by a Holder Identification Number (HIN) to review trading activity for overall compliance and improves settlement efficiency. 3.3 Existing HIN Any HIN from a former/existing Broker relationship can be transferred to Lonsec to preserve instructions. Staff establishing a new Lonsec account should indicate a HIN transfer and liaise with Lonsec`s middle office who will process the HIN transfer. 3.4 Margin lending Staff who use a margin lending facility with their account must execute all orders through Lonsec. 3.5 Options trading or CFDs Lonsec does not facilitate option trading or provide CFD or FX or futures trading (derivatives). Staff and Staff related accounts are not prohibited from trading derivatives. However, Lonsec in conjunction with LFH Group Compliance, reserves the right to restrict derivatives trading accounts and requires Staff to advise LFH Group Compliance of any derivatives trading account they hold. Staff trading in derivatives, FX or futures should note that all transactions in these securities must also be authorised in the same manner as securities transactions and are subject to hold periods. (see 3.7 below). 3.6 Confirmations Where Lonsec allows the operation of an account through another Broker for securities, derivatives, FX or futures trading LFH Services Compliance must receive an email copy of each and every confirmation issued upon a transaction, addressed to Staffconfirmations@lonsec.com.au Lonsec will configure Staff accounts for electronic confirmations and will use the Staff member s Lonsec email address as a default. Staff may advise an external email address for copy of confirmation to be sent. 3.7 Prior written authorisation required A written Staff Order must be completed for each proposed transaction using dedicated Staff order pads for all securities transactions for Staff and Staff related Accounts. For ASX listed Equities: Blue for Buy and Pink for Sell (including each order amendment and cancellation) For other Securities and Products: White order book (including each order amendment and cancellation) All Staff orders must be written out using the Staff order pad, or in the case of Sydney office Staff or absence from work, phoned through to the dealing desk by the Staff member. Staff orders cannot be relayed by third parties. The Staff Order must record the order detail as set out in the Staff order pad and also clearly instruct the duration of the order e.g. good for day only GFD or good until cancelled GUC
P 6-10 DATE PREPARED 01-11-2013 Staff related accounts, where the Staff member has no beneficial ownership e.g. spouse account, cannot be placed by a Staff member unless an authorisation from the account owner has been received by Lonsec. Note: All orders executed for Staff and Staff-Related Accounts must be completed in paper form and duly authorised. 3.8 Authorisation Authorisation MUST: be given in writing by one of the Staff Order Authorisation Officers. If in the unlikely event that there are no Authorised Officers available then a delegated Authority Officer can perform this function; and be given PRIOR to placement of the order with an Adviser, Dealer or DTR. Those able to authorise ASX listed equity orders ( Staff Order Authorisation Officers ) are: Jason Clarke Director, Lonsec David Wylie CEO Lonsec Stockbroking, RE Jeremy Pree RE Delegated Authority Jason Taylor General Manager LFH Group Compliance, LFH Adam Bold Risk and Compliance Consultant, LFH Those able to authorise orders in Non-ASX listed Securities and Products ( Staff Order Authorisation Officers ) are: Amanda Gillespie CEO, Lonsec Research Pty Ltd Paul Pavlidis COO, Lonsec Research Pty Ltd Before giving authorisation, Staff Order Authorisation Officers must: ensure all necessary Order detail is recorded on the Staff Order; the Staff members name who has written/placed the order is clearly displayed on the order; take into account the circumstances of the proposed transaction (e.g. whether the Staff or Staff-Related Person may have obtained inside/confidential information in the course of his/her duties) and anything which might materially affect the price of the financial product ( e.g. size of transaction, liquidity of stock, timing of order,); consider the Restricted List and trading embargoes (i.e. Staff may not be permitted to sell or buy when they wish to); whether there are other similar client orders in the order book requiring trading precedence; and ask whether the Staff member has sufficient cleared funds or holdings to cover settlement (see Section 5). Authorisation is to be given by writing the following on the Staff Order; Signature of Authorising Officer; together with Date and time of authorisation. Note: A person is not permitted to authorise their own dealings. All authorisations are to be in writing. A DTR cannot operate an order on his or her own account or an associated account, it must be operated by another DTR and the STAFF order must display the appropriate stamp. That is as well as the authorising officers signature being affixed, the executing DTR s signature must also be affixed, both requiring time and date. 3.9 Restricted list The Restricted List forms part of Lonsec`s embargo and Ethical Dividers procedures. The List is maintained by LFH Group Compliance from information provided by Employees or the Executive. When a stock is subject to control, the compliance unit will advise order authorises (or any other employee as deemed necessary) of either the stock or that all order approvals require liaison with compliance. Issuers and financial products will be placed on the List for a number of reasons that may include any of, Lonsec is involved in a corporate transaction which may give it access to price sensitive information not generally known to the market. Lonsec is managing an order of significance The perception, real or otherwise, that gives the appearance of Staff trading of the back of client orders This is to prevent the perception of insider trading arising. Accordingly, dealing in the financial products of the issuers will generally be prohibited for Staff and Staff-Related Accounts. If any exceptions to this rule are to be granted, this must be authorised by the Executive in conjunction with LFH Group Compliance.
P 7-10 DATE PREPARED 01-11-2013 3.10 Trading embargo release of research report Where Lonsec`s Equity Research coverage is known to, or has the possibility to influence the market behaviour of clients, trading by Staff and Staff-Related Accounts in the financial products of the issuer(s)/company(ies) in question may be banned for a period before and after release (usually 24 hours either side) of a major Research Report which commences coverage or changes a current recommendation. Analysts and Research Staff are not to deal on their Staff or Staff- Related Accounts in financial products related to an issuer known to be the subject of material, unreleased research. 3.11 Short selling Short Selling by Staff and Staff related accounts is strictly prohibited whether the account is held with Lonsec or other provider-with permission. 3.12 Placing the order Once the Staff Order (ASX-listed) is signed by Staff and authorised, the order is to be placed with an Adviser, Dealer or DTR in the usual way. Orders for options and derivatives e.g. CFDs or ASX-listed stock executed by an external entity can be placed by the relevant Staff member only, but not before the order is authorised. Orders must not to be placed verbally (note Sydney office Staff member or absent Staff member), without the paper work being complete in full. DTR s must check that order details are completed in full and refuse incomplete orders. It must be clear that the Account is a Staff or Staff-Related Account to ensure compliance with Client Order/Allocation Precedence obligations. 3.12.1 Front-Running Prohibited Placing orders to take advantage of possible market movements caused by received or expected client orders is Inside Trading. Staff and Staff-Related Accounts are not to buy or sell securities, futures contracts or other financial products while in possession of knowledge of actual or potential client orders of a material size. 3.12.2 Orders are valid until cancelled The obligation to manage incomplete orders is that of the Staff member who placed the order. Unexecuted orders, due to order limits, market conditions or any other reason, will remain in the market until they trade in full, are cancelled by the Staff member, Lonsec or purged by ASX Market Control. 3.12.3 Orders may be withdrawn at any time Lonsec and LFH Group Compliance reserves the right to cancel some or all unexecuted Staff orders from ITS at any time. In certain circumstances the stock allocated to a part-filled or completed order may be re-allocated to a client. Staff can cancel an unexecuted order at any time. 3.12.4 ANY amendments must be authorised ALL amendments to Staff orders, price or volume limits require PRIOR authorisation by the process applying to new orders. The authorising officer must decide if the amendment requires a new written order. 3.12.5 Order cancellation Instructions by Staff to cancel uncompleted or partially unfilled orders must be via a written new order that displays the order reference number of the original order being cancelled. 3.13 Minimum holding period is 48 hours Purchases must be held for a MINIMUM of 48 hours from the time of execution. Weekends and non-trading days are NOT included in the calculation of the 48 hour period. Day-trading is strictly prohibited. Exceptions to this rule can only be granted by the Executive in conjunction with LFH Group Compliance, who will consider the circumstances of the trade. 3.14 Use of suspense accounts prohibited Executions on behalf of Staff or Staff-Related Accounts must be booked directly to the Staff account. Suspense and consolidation accounts must only be used for client business. Note: NO Staff or Staff related trades are to remain unbooked overnight. 3.15 Dealings monitored, market activity may be limited or stopped Lonsec in conjunction with LFH Group Compliance reserves the right to limit or stop some or all dealings on Staff and/or Staff-Related Accounts. Any irregularities or unusual activity will be investigated. If settlement requirements are not met or transaction activity (by time spent, value and/or number of transactions) on a Staff or Staff-related account is considered by LFH Group Compliance as excessive or likely to distract the Staff member from his or her duties, then approval of further dealings by the Staff member s own or related accounts may be withheld (and subjected to any conditions Executive Management imposes) or stopped for a specified period.
P 8-10 DATE PREPARED 01-11-2013 4. Allocation to Staff & Staff related accounts Staff and Staff-Related Accounts may receive allocations in underwritings, sub-underwritings and placements of equity or other financial products where Lonsec is distributing the opportunity. 4.1 Allocation criteria for issues formally involving Lonsec Allocations to Staff and Staff-Related Accounts will be coordinated by the RM/RE s and a. For each IPO, LFH Group Compliance must be notified of the limits and terms of participation and of the Staff and Staff-Related Accounts participating before allocations are settled. Allocations and holding periods will be determined by the Lonsec Executive Committee for each issue. Lonsec will comply with restrictions imposed by the Issuer/Seller in terms of a holding period which will generally be at least two days after the issue first trades. Retraction of a Staff commitment to an allocation will only be permitted if unforeseen and exceptional circumstances arise. Any exemptions to this policy will be determined by the Executive in conjunction with LFH Services Compliance. Generally Lonsec Staff participation will not be preferenced above clients. 4.2 Non-public information Staff in the Research Department, Institutional Dealing or Underwriting Committee may be subject to additional policies and restrictions by virtue of their positions and their recent access or proximity to commercially and market sensitive information. 4.3 New issues not involving Lonsec Staff and Staff-Related Accounts are permitted to apply or subscribe for financial products underwritten, sub-underwritten or placed by an ASX Participating Organisation or an AFSL holder other than Lonsec Limited. If Staff participate in a firm allocation offered by an AFSL holder, they must immediately provide a copy of the completed documentation to LFH Group Compliance. Where an allocation is received, that is not sponsored by Lonsec; Staff must initiate sponsorship upon receipt of a holding statement. LFH Group Compliance must be informed of any allocation. In accordance with Lonsec s Market Dealing Rules (refer Section 3), sale or other market dealings in the financial products allocated are subject to a minimum holding period of two days and must be transacted through Lonsec. 5. Settlement Settlement of dealings by Staff and Staff-Related Accounts must: not involve any subsidiary of the LFH Group lending, making funds available or otherwise extending credit for purchases or allocations; and be facilitated by the account holder (i.e. Staff to provide ALL the information Settlements requires) in a timely, efficient fashion as required by Settlement Staff 5.1 Secondary market dealings 5.1.1 On-market/off-market purchases Sufficient cleared funds must be available in the settlement account by 10.00am on the third business day following the date of the transaction (i.e. T+3) Where settlement is partly or totally reliant on settlement of a sale(s) of financial products, those funds must be available by settlement on T+3 following the date of purchase. If sale proceeds are insufficient to cover the purchase(s), additional funds must be available in the settlement account. It is mandatory for Staff and Staff-Related Accounts to provide a direct debit/credit authority and to ensure at all times sufficient cleared funds are available in the settlement account. 5.1.2 On-market/off-market sales Sufficient holdings must be held when the order is placed and available on the settlement date specified on the contract note (i.e. T+3). Where Staff and Staff-Related Accounts are selling holdings which are NOT Broker Sponsored by Lonsec, the Shareholder Reference Number (SRN) and/or delivery detail must be provided on the Staff Order. Sales must not be placed for stock sponsored by another entity, except for holdings maintained with a margin lender. Under NO circumstances are sales to be made where, at the time of the sale, the relevant Staff or Staff-Related Account does not have a presently exercisable and unconditional right to vest the securities (or particular financial product) in the buyer. To do so would be a Short Sale and in breach of this policy (See 3.11). 5.1.3 Fail fees Even when settlement fails through no fault of the Staff member or Lonsec (e.g. margin lender s fault), the Staff or Staff- Related Account will bear any fail fees.
P 9-10 DATE PREPARED 01-11-2013 5.1.4 Derivative products not traded on ITS Dealings in Exchange Traded Options, CFDs, LEPOs or Futures permitted by Section 2 must be settled as required (generally T+1) by the licensed executing intermediary. Settlement regulations do not permit them to extend credit 5.1.5 Purchases or sales - failure to settle as required Lonsec will act to ensure its compliance obligations are met, which may include exercise of its right to sell-out or buy-back sufficient securities or financial product on behalf of the Staff or Staff-Related Account to cover the exposure, at the risk of the account holder. Any remaining deficiency would then be payable immediately. All failed settlements on a Staff account must be advised to LFH Group Compliance by back office Staff managing failed settlements. Lonsec will not settle transactions early i.e. prior to CHESS settlement date. 5.2 Primary market dealings Lonsec is prohibited from paying application, subscription or exercise (e.g. instalment receipt/company option) monies on behalf of Staff or Staff-Related persons or entities unless sufficient cleared funds have already been provided to Lonsec. 6. Reporting new Staff & Staff related accounts To ensure compliance with Client Order/Allocation Precedence, Order Authorisation and related regulatory requirements, all Staff of Lonsec must declare/confirm: at induction, all Staff and Staff-related persons or entities (refer to definitions) for which an account is to be opened; annually, all Staff and Staff-Related persons or entities and their Accounts at the same time as completing the Annual Affiliation Reporting Statement Questionnaire; the opening of a new Staff or Staff-Related Account by having the New Account Application Form checked by the RE/RM as stipulated in section 3 New Staff Account Procedures. 7. Accounts/dealing at other firms or for Staff of other firms 7.1 Accounts & dealing at other firms It is Lonsec s policy that all Staff and Staff-Related Accounts that facilitate trading in ASX-listed products are to be held, and Broker Sponsored, by Lonsec. Upon commencement of employment with Lonsec accounts held at other ASX participating organisations must be closed and the HIN and all holdings are to be transferred. This policy is a vital component to Lonsec s Conflicts of Interest & Risk Policy as it allows LFH Group Compliance to monitor Staff trading against the Group s corporate and research activities, and as such the LFH Group and Lonsec`s Management and Board will view breaches of this policy as a serious matter. Staff are strictly prohibited from operating an existing account, or establishing an account with another ASX participating organisation, unless an exception is approved Exceptions to this policy must be approved by LFH Group Compliance and Lonsec Executive, examples which will be considered are as follows: if Lonsec does not provide direct access to the market for a particular product (e.g. ASX Exchange Traded Options, LEPOs, CFD s), and a member of their Immediate Family (refer definitions) is employed or conducts their trading at another ASX Participating Organisation (i.e. a Stockbroker) and they operate their account independently. To do so would require: For Staff accounts the usual prior order approval by Lonsec Limited; copies of confirmations sent directly to LFH Group Compliance by the executing party for all transactions ; and providing in advance the detail of the type and number of accounts opened at the other firm. Following approval to open or maintain account(s) and deal elsewhere, all orders: must be authorised (including any amendments or cancellation) in accordance with the usual procedure described in Section 3. Authorisation may be denied; copy of all confirmations to be provided to LFH Group Compliance; and subject to the usual and relevant requirements of this policy. For Staff-Related Accounts LFH Group Compliance must receive a letter from the immediate family member requesting permission to operate the independent account with an entity other than Lonsec limited, and in these circumstances. Arrange for a copy of each confirmation issued by the executing party for all such transactions directly emailed to LFH Group Compliance. Detail of holdings held elsewhere must be maintained by the Staff member and be notified and made available for inspection to LFH Group Compliance if requested.
P 10-10 DATE PREPARED 01-11-2013 7.2 Accounts & dealing for Staff of other firms are prohibited Unless authorised by a Director in conjunction with LFH Group Compliance, Staff of another ASX participating organisation may not open their Staff or Staff-Related Accounts at Lonsec. If a Staff member believes Staff or Staff-Related persons or entities from another firm have an account which has not been authorised and/or are dealing through Lonsec, LFH Group Compliance must be notified. Authorisation may be granted under certain circumstances and subject to the other entity confirming the account is approved for opening and providing an address for copy confirmations to be sent to relevant compliance.