HFA Holdings Limited (“HFA”) has implemented a Trading Policy which regulates the manner in which any Director, Key Management Personnel, Officer, Compliance Committee Member and Employee can buy or sell shares in HFA, and requires that they conduct their personal investment activities in a manner that is lawful and avoids conflicts between their own interests and those of the Group and its clients. The policy seeks to ensure compliance with the Corporations Act (2001), Corporations Regulations 2001 and Australian Securities Exchange Limited (ASX) Listing Rules.
The policy specifies trading windows as the periods during which trading in shares can occur. These trading windows will generally be the six week period following the release of HFA’s full year or half year results and following the holding of HFA’s Annual General Meeting. Trading is prohibited despite a window being open if the relevant person is in possession of non-public price sensitive information regarding the HFA Group.
Any designated Officer to whom this policy applies wishing to trade in HFA’s securities outside the nominated trading window must first obtain written approval from the Board, via the Company Secretary. The designated Officer must notify the Company Secretary immediately upon acquiring/disposing of HFA’s securities.
Nothing in this policy shall authorise any person to act in contravention of the insider trading provisions of the Corporations Act (2001).