Insider Trading Policy
Insider Trading Policy
Employees which have price-sensitive information about a company's shares or other securities (including Westpac's) which isn't generally available to others, must not use this information in deciding whether or not to buy or sell those shares or other securities.
In addition, they must not give this inside information to anybody else who is likely to use it for the same purpose or who might pass it on to others, including fellow employees whose role within Westpac is to trade in shares or other securities.
Rules for all employees with inside information
Employees who have price-sensitive information about a company's shares or other securities (including Westpac's) which isn't generally available to others: - Must not subscribe for, buy or sell shares, other securities of the company, or other price sensitive products to which the inside information relates, either for themselves, or for another person
- Must not get another person (whether a family member, friend, associate, colleague, or your broker, investment adviser, private company or trust) to subscribe for, buy or sell the affected shares or other securities or other price sensitive products for the employee, for another person or for themselves
- If an employee has an arrangement with an agent to conduct discretionary trading on their behalf, they should ensure that the affected shares or securities or other price sensitive products are excluded from those shares, securities or other price sensitive products that the agent is authorised to buy and sell
- Must not, either directly or indirectly, give the inside information, or allow it to be given to another person who they know, or should know, would be likely to do any of the prohibited things described above
- Must not subscribe for, acquire or dispose of, offer or agree to acquire or dispose of, or influence others (including family, associates, colleagues, private company or trustee) with regard to, shares, other securities, or other price sensitive products relating to a company in respect of which they are the relationship manager, or if they are otherwise involved in any way in administering Westpac's relationship with that company
- Must not communicate inside information to anybody who works for the Westpac Group except in accordance with the rules and policies of the relevant business division or as specifically directed by Compliance
- Must not communicate inside information to anybody who works in the Westpac Group if it does not relate to the business Westpac transacts with its customers
- Must not get traders or distributors employed by the Westpac Group to buy or sell securities or other price sensitive products on their behalf on the basis of inside information
- If an employee liaises with industry analysts or business journalists working on the business activities of Westpac, they must not give them any inside information about Westpac, or confirm for them any suspicions or hunches which they may have, even if these hunches are based on their own research and analysis
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Additional rules for Prescribed Employees
Some jobs within the Westpac Group by their nature bring employees into contact with important information about Westpac all or most of the time. These employees have been identified within the Westpac Group as "Prescribed Employees."
Prescribed Employees are employees in a position of trust within the organisation, and are expected to behave ethically and in compliance with both the spirit and letter of the insider trading policy at all times.
There are four basic rules that Prescribed Employees must follow in addition to the above inside information rules. - Prescribed Employees must not buy or sell Westpac shares, or other Westpac derivatives involving Westpac shares or other Westpac securities, without first notifying Westpac
- Unless the Prescribed Employee has prior permission from Westpac, s/he must not arrange for another person to try to buy or sell Westpac shares or other Westpac securities for another employee, themselves or someone else
- Prescribed Employees must not allow inside information to be given to a person whom they should know is likely to participate in insider trading. Generally, this means that any information a Prescribed Employee has about Westpac which has not been made public, and which may affect the share price if it became public, should only be given to people in Westpac who need to know the information as part of their job
- Prescribed Employees may only trade in Westpac shares or other Westpac securities or derivatives involving Westpac shares or other Westpac securities during a Trading Window. Trading Windows commence two days after the release of Westpac's half yearly and yearly results. The windows are normally 56 days in length. However, the Chief Compliance Officer has the discretion to extend each window by up to 7 days if having a 56 day window would unreasonably restrict the exercise of employee scheme entitlements
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