Memorandum to Employees
Insider trading is the practice of dealing in a company's securities (ie. shares or options) by a person with some connection with a company (eg an employee) in possession of information generally not available to the public, but may be relevant to the value of the company's securities. It may also include the passing on of this information to another. Legally, it is an offence which carries severe penalties, including imprisonment.
In summary, as an employee of the Company you must not whether in your 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, or procure another person to do so if:
- you, the employee, possess information that a reasonable person would expect to have a material effect on the price or value of the securities if the information in your possession were generally available; an
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you, the employee, know, or ought reasonably to know, that:
- the information is not generally available; and
- if it were generally available, it might have a material effect on the price or value of the securities in the Company.
Further, as an employee of the company, you must not either directly or indirectly pass on this kind of information to another person if you know, or ought reasonably to know, that this other person is likely to deal in the securities of the Company or procure another person to do so.
The above comments are not intended to be an exhaustive analysis of the restrictions imposed on, and the very serious legal ramifications of, insider trading. If you are unsure of the extent of your obligations and wish to obtain further advice in this matter, you may contact the Company Secretary.
In addition, to comply with the Continuous Disclosure obligations of the Australian Stock Exchange (“ASX”), the company is required to immediately disclose to ASX any information that a reasonable person would expect to have a material effect on the value of the company’s securities. Should you be in possession of any such information, you should advise the Managing Director or Company Secretary as a matter of priority.