(1) This Policy is effective from 1 August 2024. (2) Insider trading is prohibited under the Corporations Act 2001 (the Act). This Policy explains the type of conduct that is prohibited under the Act and provides guidance to persons who are privy to insider information on how they can recognise and avoid Insider trading. (3) This Policy must be read in conjunction with the Code of Conduct and the Declaration of Interest procedure. (4) This Policy applies to: (5) University persons are in a position of trust and required to act honestly and to exercise the degree of care and diligence that a reasonable person would exercise if they were performing the same role and privy to inside information. (6) Additional standards of personal and professional behaviour apply to Deakin staff and associates under the University's Code of Conduct. (7) Insider trading is a specific crime under the Corporations Act involving misuse of insider, price-sensitive, confidential information for financial gain either through directly investing in stocks or similar financial products (securities) or by providing that information to other persons for the same purpose (tipping). Insider trading can result in severe fines and/or imprisonment and civil liability. (8) University persons must not engage in Insider trading by either: (9) The Deakin Group comprises the following entities: (10) Staff members found to have engaged in insider trading are liable to disciplinary action under the University's Staff Discipline procedure. (11) An insider is any person who possesses information about securities that is not generally available and where that information is price sensitive and the person knows or ought reasonably to know that the information is not generally available and is price sensitive. (12) An insider is also anyone who has inside information, whether or not they are associated in any way with the company concerned. (13) A University person can only deal in Deakin Group securities if that person does not have any insider information and has received the written permission of the Chief Financial Officer. (14) Any University person who is unsure of the information that they have in their possession and whether they can deal in Deakin Group securities should contact the Director, Commercial Finance. (15) All breaches of this Policy should be immediately reported to the Chief Financial Officer. (16) There is no attendant procedure. (17) For the purpose of this Policy:Insider Trading Prevention Policy
Section 1 - Preamble
Section 2 - Purpose
Section 3 - Scope
Section 4 - Policy
Obligations of University persons
Insider trading is prohibited
Who is an insider?
When can I deal in Deakin Group securities?
What if I am not sure?
Reporting insider trading breaches
Section 5 - Procedure
Section 6 - Definitions
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For the purposes of this Policy these people are described as 'University persons'.
Top of PageThe entities that comprise the Deakin Group are subject to change. If there is any doubt that an entity is part of the Deakin Group, enquiries should be made to the Director, Commercial Finance before any trading occurs.