Employees’ Transactions

Transactions of private nature in any securities/investment carried out by ABC Group’s employees are subject to specific rules that must be permanently and strictly observed.

All members of the staff, including recently engaged employees receive a copy of this Policy at the start of their activities.

Certain restrictions apply, particularly in case you have inside information.

In no circumstances it is permitted to obtain personal benefits resulting from access to confidential information.

You may not trade securities based on inside information. This implies not to trade, not to offer instructions, neither cause any person to trade listed stocks or securities in case you have information you believe that is not publicly known and which may affect the prices of those securities or the companies involved.

This applies irrespective of the source or how this information was obtained, and includes:

a) purchase and sale for yourself, your relatives, friends and third parties;

b) advisory or information to third parties to sell or buy.

Note: information with price implications is defined as information that could affect the price of securities if it was publicly known.

Examples:

  • Stake control or amalgamation proposals;
  • Potential insolvency;
  • Changes in management;
  • New product or discovery.