All Company directors, officers, employees are prohibited from trading in the Company’s shares, options or other securities or derivatives while in possession of unpublished price-sensitive information concerning the Company.
Sabina Corporation Limited’s price-sensitive information is information, which a reasonable person would expect to have material effect on the price or value of the securities in the Company. It is assumed for the purpose of this policy that some of the Company’s directors, officers, and employees are likely to be in possession of price-sensitive information by virtue of their position. Accordingly, unless there are unusual circumstances, as determined by the Board, trading in the Company’s shares, options or other securities or derivatives by directors, officers, and employees is limited to the following periods:
- Within five (5) business days after the date of release of the Company’s half-year and annual results to the ASX.
- From the date of lodgment of the Company’s printed annual report with the ASX through to five (5) business days after the holding of the Company’s annual general meeting.
- Any period where a prospectus has been issued and is current (such as a rights issue) and where the person is not in possession of any price-sensitive information which has not been made publicly available to the market.
Directors, officers, and employees are prohibited from trading in the Company’s shares in the following circumstances:
- If in possession of price-sensitive information
- In the two (2) months preceding the lodgment of the half-year and annual results to the ASX, and
- Trading for a short-term gain.
Directors, officers, and employees are prohibited from dealing in the securities of outside companies about which they may gain price-sensitive information by virtue of their position with Sabina Corporation Limited.
In addition, Sabina Corporation Limited requires that:
- Directors must inform the Chairman of a proposed trade in the Company’s shares, options or other securities or derivatives prior to any trade and confirm they are not in possession of any unpublished price-sensitive information.
- Officers and employees are required to notify the Company Secretary of a proposed trade in the company’s shares, options or other securities or derivatives prior to any trade and confirm they are not in possession of any unpublished price-sensitive information.
Directors, officers and employees are required to notify the Company Secretary in writing of any dealings in the Company’s shares, options or other securities or derivatives within three (3) business days of the trading and keep the register of their dealings current.
The requirements imposed by this policy are separate from and additional to, the legal prohibitions in the Corporations Act on insider trading.
There may be instances where there is determination that these policies may be circumvented. Consideration can be given to circumstances where an individual has a special need to dispose of their shares, options or other securities or derivatives (for reasons such as financial hardship) where an exception can be made to this policy only after determining that there is no breach of appropriate laws. |
