Policy for Material Non-Public Information

POLICY

Employees who have access to Confidential Information are not permitted to use or share that information for purposes of trading securities (such as ASX-listed securities) or for any other purpose except the conduct of our business. Insider trading (or dealing) laws and regulations globally prohibit buying or selling a company’s securities while in possession of Material Non-Public Information about that company. You can also violate these laws by disclosing Material Non-Public Information to another person. If you make such a disclosure or use such information, you can be punished, even if you yourself stand to make no financial gain.

DEFINED TERMS

Confidential Information

Confidential Information is any competitively sensitive and/or material non-public information that is maintained or otherwise handled by Executive Agents, Executive Agents’ employees or others with whom Executive Agents does business, including, but not limited to:

  • non-public information used for, or obtained from an individual for the purpose of assisting them find new employment opportunities, including in the preparation of resumes and curriculum vitaes, covering letter writing and selection criteria responses;
  • general career advice, career coaching and recruitment assistance;
  • Special Personal Information.

Material Information

Material Information means any information that: (i) might have an effect on the market for a Security generally; or (ii) might affect an investment decision of a reasonable investor. Examples of Material Information may include, but are not limited to: sales results; earnings or estimates (including reaffirmations or changes to previously released earnings information); dividend actions; strategic plans; new products, discoveries or services; important personnel changes; acquisition and divestiture plans; financing plans; proposed securities offerings; marketing plans and joint ventures; government actions; major litigation, litigation developments, or potential claims; restructurings and recapitalizations; the negotiation or termination of major contracts; and potential or pending credit rating actions. If there is any question as to whether or not a particular piece of information is Material Information, it should be assumed that it is Material Information.

Material Non-Public Information

Material Non-Public Information refers to that information that is both Material Information and Non-Public Information.

Special Personal Information

Special Personal Information is:

  1. an individual’s name in combination with the individual’s:
  2. Tax File Number, passport number, driver’s licence number or other government-issued identification number;
  3. Financial account number, with or without any code or password that would permit access to the account;
  4. Credit card number; or
  5. Employee compensation information, performance evaluations and other information contained in employee personnel files; or
  6. an individual’s name or a unique identification number in combination with race, religion, ethnicity, medical or health information, background check information or sexual orientation.

Special Personal Information is a type of Personal Information.

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