Maintain insider trading policy + share trading window (listed entities)

ASX Listing Rule 12.12 requires written policy on directors + senior managers trading entity securities.

criticalcurrentongoingCriminal liability

Who must comply

ASX-listed entities + their KMP.

What triggers it

Being listed.

When due

Continuous; trading windows enforced around price-sensitive announcements.

Evidence required

Published policy; trading window register; clearance approvals.

Max penalty

Insider trading criminal up to 15 years prison + 3× benefit; civil to financial-services max

Summary

ASX Listing Rule 12.12 requires listed entities to publish a written share trading policy covering directors + key management personnel. Must specify trading windows, blackout periods around results announcements, requirements for clearance, and prohibition of trading on inside information (Corporations Act s 1043A).

Enforced by

Source legislation

Entity types

company

Topics

corporate-governanceinsider-tradinglisted

Source: https://asx.com.au/listings/listing-rules-guidance. Rules Mate is not a law firm. Always verify against the live regulator source before acting.