ABP.CCS.003 Securities Dealing Policy Overview

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Questions and Answers

What should an Affected Person do if in doubt about a provision of the Policy?

Consult the Company Secretary before taking any action. (correct)

Proceed with the transaction without consultation.

Wait for the next board meeting to clarify doubts.

Seek advice from a third-party consultant.

Who are considered Affected Persons according to the Policy?

All employees of the Bank.

Employees, senior management, committee members, and directors of the Bank and its subsidiaries. (correct)

Members of Shareholders Audit Committee only.

Directors of the Bank's subsidiaries.

What does 'Dealing' refer to in the context of this Policy?

Property acquisitions.

Bank account transactions.

Securities transactions related to the Bank. (correct)

Personal investments of employees.

Who is meant by 'Company Secretary' as per the Policy?

A person authorized to perform Company Secretary functions. Signup and view all the answers

What does the term 'Off-Market Dealing' in the Policy refer to?

Dealing with securities not on a recognized exchange. Signup and view all the answers

When should an Affected Person consult the Company Secretary?

Before undertaking any transaction involving the Bank's securities. Signup and view all the answers

Who has the ultimate responsibility for the Securities Dealing Policy in Access Bank Plc?

Board of Directors Signup and view all the answers

What is the role of the Chief Conduct and Compliance Officer with regards to the policy?

Monitor adherence and observance Signup and view all the answers

What is the responsibility of the Human Resources Group concerning the policy?

Keep records of breaches Signup and view all the answers

Who is in charge of advising on the applicability and consequences of breach of the policy?

Company Secretary Signup and view all the answers

What does the Securities Dealing Policy of Access Bank Plc exclude?

Investment in Unit Trusts Signup and view all the answers

How does the Policy treat breaches in terms of disciplinary actions?

Applies sanctions without prejudice to statutory ones Signup and view all the answers

What is the main purpose of the Securities Dealing Policy mentioned in the text?

To provide a framework for compliance with relevant regulations and prevent insider trading Signup and view all the answers

Who are considered 'Affected Persons' according to the Securities Dealing Policy?

Directors, Senior Management, Employees, and insiders of the Bank and its related companies Signup and view all the answers

What is the responsibility of Affected Persons regarding their dealings as per the text?

To ensure their dealings comply with the Policy and do not constitute insider trading Signup and view all the answers

What does the text mention as a key feature of the Policy's compliance standards?

Providing a framework for seamless implementation Signup and view all the answers

What is the purpose of the internal review mechanism within the Policy?

To measure compliance and effectiveness Signup and view all the answers

Which regulatory bodies' provisions must Affected Persons comply with under this Securities Dealing Policy?

CBN Code, SEC Rules, and Investments and Securities Act 2007 Signup and view all the answers

Study Notes

Securities Dealing Policy

The policy is applicable to Access Bank Plc and its subsidiaries, and is intended to ensure compliance with the CBN Code, SEC Rules, and ISA provisions on dealing with the Bank's securities.

Roles and Responsibilities

The Board of Directors has ultimate responsibility for the policy and must initiate and maintain measures to ensure adherence.
The Chief Conduct and Compliance Officer monitors adherence, creates awareness, investigates non-compliance, and reports to the Board Audit Committee.
The Human Resources Group deals with breaches, facilitates disciplinary action, and keeps records of breaches as part of employee records.
The Company Secretary provides advice on the policy, its applicability, and consequences of breach.

Exclusions and Repeal

Investment in Unit Trusts and Collective Investment Schemes are excluded from the policy.
This policy repeals and supersedes the existing Non-Dealing Periods Policy of the Bank.

Scope and Purpose

The policy aims to provide a framework for compliance with relevant regulations and laws.
It is intended to prevent Affected Persons from abusing or appearing to abuse privileged information or benefiting from material non-public information.

Definitions

"Affected Persons" include employees, senior management, members of the Shareholders' Audit Committee, and Directors of the Bank and its subsidiaries or a Related Party.
"Dealing" encompasses various activities, including sales, purchases, agreements, options, grants, and transfers related to the Bank's securities.

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Description

Explore an overview of the ABP.CCS.003 Securities Dealing Policy which is aligned with the Central Bank of Nigeria's Code of Corporate Governance, Securities and Exchange Commission's Rules, and the Investments and Securities Act 2007. Understand the purpose and framework provided by this policy.