Page 71 - Phil Reddin Financial Services Ltd DRAFT V1

7.9 POLICY ON DEALING IN SHARES AND OTHER FINANCIAL INSTRUMENTS

7.9.1 Policy
This policy is issued to all EBS Group staff members. Where the policy refers to Staff it includes staff
of EBS Head Office and branches, (including managers and Assistant Managers) staff of EBS Agents &
staff of EBS Tied Branch Agents, (including Principals), staff of EBS Limited, and staff of subsidiary
companies, EBS Mortgage Finance and Haven Mortgages, as an interim measure.

7.9.2 Introduction and Scope
Staff should be aware that, by virtue of their employment (or, any connection) within a financial
institution, they could come into possession of inside information. Inside information is information
of a precise nature which has not been made public, relating directly or indirectly, to one or more
issuers of financial instruments (e.g. publicly quoted companies) or one or more financial instruments
which, if it were made public, would be likely to have a significant effect on the price of those financial
instruments or on the price of related derivative financial instruments.

The laws and regulations on dealing in financial instruments, e.g. shares and other securities, are strict
and the sanctions are severe - Insider Dealing is a criminal offence. For that reason and to provide
adequate guidance to Staff on our legal and regulatory obligations and ethical standards, we need a
clear policy governing the personal dealing of Staff to protect both the individual and the organisation
from breaching their obligations. The key obligation contained in this policy is that staff of EBS must
not deal in financial instruments when they possess inside information.

Financial instruments are defined in the Notes (note 4), which form part of this policy, but for ease of
reference we will refer to "shares" throughout this policy document. This policy applies to the personal
share dealing of all staff (see notes 1 and 2).

Any questions about this policy should be referred to Regulatory Compliance.

Risk Characteristics

The misuse of inside information (insider dealing) is a criminal offence. This policy is specifically
intended to:

• Protect staff from contravening the law.
• Assist staff in demonstrating ethical conduct in dealing in shares.
• Preserve the good reputation of EBS and their staff in all its markets.

Policy Statement

• Staff must not deal, or recommend or induce anyone else to deal in the shares or other financial
instruments (as defined in the notes) of any company, if they possess inside information
concerning that company, whether they are in possession of that information by reason of their
employment within EBS, their association with EBS as a Tied Branch Agent or Agent, or otherwise.
• All staff are prohibited from dealing or recommending or inducing anyone else to deal in the
shares of Allied Irish Banks, p./.c. during its 'Close Periods' (note 5).
• All staff must obtain permission before they deal in the shares of Allied Irish Banks, p./.c.
• Under this policy, any such permission to deal must be obtained in writing from the relevant
Management Team member and must if granted, be exercised and executed within 5 business
days of being approved. There is an onus on the staff member to retain the record of permission
granted. EBS will retain the copy for a period of 5 years.

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