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SECURITIES DEALING POLICY

1.0 INTRODUCTION dit Committee and the Board Audit Committee of
the Bank;
This Policy shall be read in conjunction with the Central
Bank of Nigeria’s Code of Corporate Governance for Banks “Bank” means Access Bank Plc
and Discount Houses in Nigeria (‘CBN Code’); the Securi-
ties and Exchange Commission’s Rules (SEC Rules) and the “Company Secretary” means the Company Sec-
Investments and Securities Act 2007 (ISA). retary of Access Bank Plc or any person duly autho-
rised to discharge the functions of the Company
Secretary for the time being in force;

2.0 PURPOSE “Dealing” means:

This Policy aims to provide a framework for compliance a. any sale or purchase of, or agreement to sell or pur-
with the CBN Code, the SEC Rules and the ISA provisions chase any securities of the Bank;
on dealing with the Bank’s Securities by Directors, Senior
Management and Employees of the Bank and its subsidiar- b. the grant to, or acceptance by such a person, of any
ies or a related company and all insiders (hereinafter called option relating to such securities or of any other
“Affected Persons”). It is intended to ensure that Affected right or obligation, present or future, conditional
Persons do not abuse, or place themselves under the sus- or unconditional, to acquire or dispose of any such
picion of abusing privileged information or taking or bene- securities;
fiting from material non-public information at their disposal
or which comes to their possession during the course of c. the acquisition, disposal, exercise or discharge of, or
their duties, especially at periods leading up to the an- any dealing with, any such option, right or obligation
nouncement of the Bank’s financial results. in respect of such securities;
The Policy contains appropriate compliance standards and d. dealings between Directors and/or employees of
procedures that guaranty seamless implementation. It the Bank;
provides for internal review mechanism with a view to mea-
suring compliance and effectiveness. Ultimately, it is the e. Over the Counter dealings;
responsibility of Affected Persons to ensure that none of
their dealings constitute insider trading. If an Affected Per- f. Off-Market Dealing; and,
son is in doubt about any provision of this Policy, the person
should consult the Company Secretary prior to undertaking g. transfers for no consideration.
any transaction on the Bank’s securities or encouraging or
procuring someone else to so deal. “Director” means any person who occupies the
position of a director in Access Bank Plc, or in any of
its subsidiaries;

3.0 DEFINITIONS “employee” means any person engaged under a
contract of employment with the Bank or any of its
3.1 The following terms have the following meanings subsidiaries, and any other persons engaged by a
unless the context otherwise requires: third party service provider or outsourcing agency
to provide support services to Access Bank Plc or
“affected Persons” mean employees, senior man- any of its subsidiaries;
agement, members of Shareholders Audit Com-
mittee and Directors of the Bank and its subsidiaries “Holding” means any legal or beneficial interest,
or a Related Party; direct or indirect in the Bank’s securities;

“audit Committee” means both the Statutory Au- “Insider” shall include members of Audit Commit-

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Annual Report & Accounts 2017