Page 137 - ACCESS BANK ANNUAL REPORTS_eBook

tee, Directors or employees of Access Bank and price-sensitive information.
any of its subsidiaries, a related company and its
employees, a company or firm engaged in a profes- 4.2 The Policy is designed to comply with applicable
sional or business capacity with the Bank or any of statutory and regulatory obligations, ensuring that
its subsidiaries and their employees, including any businesses are conducted in line with industry stan-
shareholder who holds 5% or more of any class of dards and relevant regulatory requirements as well
the Bank’s securities or a similar holding in any of its as protect proprietary or confidential information
subsidiaries; that may be in possession of such persons from
being abused or misused.
“related Party” shall mean a spouse or partner
or any other dependent relative who lives with the 4.3 In order to avoid a potential risk of speculative trad-
Affected Persons or for whom the Affected Person ing as well as to encourage Affected Persons to
provides material financial support. This also in- trade for investment purposes, persons who are
cludes those parties over whose trading activity the presumed to possess some privileged information
Affected Persons has a direct or indirect beneficial must hold their personal and privies’ account po-
interest, control or investment influence. sitions for a minimum of 15 (fifteen) calendar days
from the date of such presumption before any
“Securities” means any securities of Access Bank trade instructions can be executed.
Plc admitted to trading on a Stock Exchange;
4. 4 Any person who is precluded by this policy from
“Securities Dealing” means trading in the Bank’s dealing in the Bank’s securities must not encourage
shares or any change whatsoever to the holding of any other person or Related Party to do so and must
securities of which the holder is an Affected Person refrain from disclosing such material non-public in-
at a period when an Affected Person is in posses- formation or opinions which might likely lead to an-
sion or deemed to be in possession (actual or con- other person trading on that information.
structive) of material non-public information;
4. 5 It is recognised that Affected Persons perform
“unpublished price-sensitive information” different roles and functions within Access Bank
means information which: Group with attendant different exposures to mate-
rial non-public information. It is an obligation there-
a. relates to particular securities of the Bank; fore for all Affected Persons to discharge their duty
of care and contractual responsibility by ensuring
b. is specific or precise; that the information obtained by virtue of their re-
spective positions is not communicated to a Relat-
c. has not been made public; and ed Party which may induce such party to trade on
the Bank’s securities.
d. if it were made public would likely have a significant
effect on the price or value of any security.

5.0 NON-DEALING PERIODS

4.0 PROHIBITION OF SECURITIES DEALINGS Save as otherwise communicated in writing by the Compa-
ny Secretary, the following periods shall be deemed to be
4.1 Affected Person, Insiders and Related Parties shall non-dealing periods:
not deal in any securities of the Bank in a manner
and at the period that suggests he is in possession 5.1 A period of 30 days prior to the publication of the
of privileged information whether actual or con- Bank’s Quarterly Profit Forecast or its submission to
structive. For clarity of purpose, any such persons regulatory authorities whichever occurs first;
shall be deemed to be in constructive possession of
material non-public information where; 5.2 A period of 30 days prior to the publication of the
Bank’s Quarterly Unaudited Accounts or its submis-
e. Such information is in the possession of a class or a sion to regulatory authorities whichever occurs first;
group of persons to which such person belongs; or
5.3 A period of not less than 30 days prior to the Audit
f. by virtue of such person’s duties, job description, Committee’s consideration of the Bank’s Audited
sphere of service or business relationship with the Accounts;
Bank or any of its subsidiaries, he would reason-
ably be expected to possess such unpublished 5.4 Any period after Board’s approval of the Bank’s Au-

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Annual Report & Accounts 2017