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• Staff must not disclose inside information to any other person unless such disclosure is made in
the normal course of the exercise of their duties.
• Staff are prohibited from engaging in personal account dealing which may endanger or adversely
affect the business or the reputation of EBS, or which may conflict with or interfere with the
performance of their duties, or which may result in a breach of any duty to customers of EBS.
• Staff personal account dealings in AIB shares must be through a recognised and authorised
stockbroker and staff must be in a position to meet all their obligations under such transactions
• Staff must confirm, when requested, that they have read, understood and agree to comply with
this policy.
• Failure to observe this policy will be regarded as serious misconduct and could constitute grounds
for disciplinary action.

Exclusions

There are no exclusions to this policy. Staff should seek the advice of Regulatory Compliance on any
issues of doubt in the application of this policy.

NOTES to Staff Share Dealing Policy

1. Personal dealing means dealing by staff on his/her own behalf or their dealing on behalf of or
through another party.
2. Dealing - in the context of this policy, means buying, selling, subscribing for or underwriting shares,
or offering or agreeing to offer shares, either as a principal or as an agent, or inducing or
attempting to induce others to so do. It includes entering into a contract (including a Contract for
Differences) the purpose of which is to secure a profit or avoid a loss by reference to fluctuations
in the price of any shares of a company (e.g. spread betting - which must be through an authorised
intermediary). It includes the transfer of shares to a non-connected party.
3. Permission to deal, when required, may only be granted by a member of Management Team and
must be in writing or electronic form.
4. Shares and Financial Instruments mean:
• shares in companies and other securities equivalent to shares in companies,
• corporate bonds and other forms of securitised debt, which are negotiable on the capital
market (e.g. the Irish/London Stock Exchange);
• any other securities normally dealt in giving the right to acquire any such transferable
securities by subscription or exchange or giving rise to a cash settlement, excluding
instruments of payments;
• financial-futures contracts, including equivalent cash-settlement instruments;
• equity swaps;
• options to acquire or dispose of any instrument falling into these categories, including
cash settlement instruments — this category includes, in particular, equity options;
• derivatives on commodities;
• spread betting and Contracts for Differences (CFDs) on any instrument falling into these
categories; and contracts involving any related indices
• any other instrument admitted to trade on a regulated market in an EU Member State or
for which a request for admission to trading on such a market has been made.

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