Redbank Energy’s Securities Trading Policy regulates the manner in which Directors of Redbank Energy entities and senior management of the businesses wholly-owned by the Redbank Energy Group can trade in Redbank Energy securities and other financial products relating to the performance of Redbank Energy securities. The Policiy requires that Directors, staff and management conduct their personal investment activity in a manner that is lawful and avoids conflicts of interests between their personal interests and the interests of Redbank Energy.
The specific objective of the Policy is to clearly specify the obligations and procedures for Directors, staff and management in relation to trading in Redbank Energy securities so as to minimise:
- any potential for breach of the prohibitions on insider trading contained in the Corporations Act; and
- the chance that misunderstandings or suspicions arise regarding Director, staff or management trading.
The Policy specifies trading windows as the periods during which trading in Redbank Energy securities can occur. These trading windows will generally be up to four week periods following the release of Redbank Energy’s full year or half year results and the offer period under any prospectus. It is a matter for the Board to determine whether it is appropriate to open the trading window at any particular time. Also, following the opening of a trading window, the window may be closed at any earlier time if appropriate.
Trading in Redbank Energy securities is prohibited by Directors, staff and management despite a trading window being open if the relevant person is in possession of non-public price sensitive information regarding Redbank Energy.
The Policy also:
- prohibits Directors, staff and management communicating non-public price sensitive information to another person who might then trade in Redbank Energy securities, or procure another person to trade in Redbank Energy securities;
- provides an obligation on Directors, staff and management to seek to ensure that any third parties who come into possession of non-public price sensitive information preserve the confidentiality of that information and do not trade whilst in possession of that information;
- sets out specific procedures to be followed by Directors and key management personnel in relation to pre-notification of an intention to trade in Redbank Energy securities during a trading window, as well as notification following confirmation of a trade;
- extends the restrictions on trading in Redbank Energy securities to the extent it is within a Director’s, staff member’s or manager’s power to do so, to:
– a spouse or partner;
– other relevant family members;
– a company or trust over which the relevant person has influence or control;
– a trust where the relevant person is a beneficiary; and
– any other person over whom a Director, staff member or management has investment control or influence;
- prohibits a Director, staff member or management trading in securities of other listed entities with which Redbank Energy may be dealing and where that person possesses non-public price sensitive information concerning the other listed entity; and
- sets out the circumstances in which a dealing in Redbank Energy securities outside of a designated trading window is permitted (i.e. as contemplated by the ASX Listing Rules).