Securities Trading (including Inside Information)
The purpose of this Policy is to provide guidance to Directors and Employees (including Key Management Personnel) for on-going compliance with legal obligations relating to trading or investing in financial products managed by Dexus.
The principle objectives are:
- the avoidance of insider trading including influencing others to trade in securities resulting from inside information
- the avoidance of actual, perceived or potential conflicts of interest with Dexus or its clients
- to impose limitations on short term trading
- compliance with ASX Listing Rules, ASX Principles of Good Corporate Governance and the Corporations Act
Dexus is committed to maintaining its strong reputation. Adherence to our policies and procedures assists us in achieving this. While compliance with legislation and regulatory guidelines is mandatory, we expect our Employees (especially in relation to securities trading) to support and promote the spirit of the legislation and guidelines.
Directors and employees should also be aware of the possible reputational damage resulting from trading in Dexus securities in periods where the market may perceive that Directors or employees are in possession of price sensitive information.
As a guiding principle, Directors and employees should ask themselves:
If the market was aware of all the current circumstances, could the proposed dealing be perceived by the market as the employee taking advantage of his or her position in an inappropriate way? How would it look if the transaction was reported in social media or on the front page of a newspaper? (The Media Test)
If the Director or employee is unsure, he or she should consult the Company Secretary.
Where any approval is required for a dealing under this Policy, approval will not be granted where the dealing would not satisfy the Media Test.