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.
Who are considered Affected Persons according to the Policy?
Employees, senior management, committee members, and directors of the Bank and its subsidiaries.
What does 'Dealing' refer to in the context of this Policy?
Securities transactions related to the Bank.
Who is meant by 'Company Secretary' as per the Policy?
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What does the term 'Off-Market Dealing' in the Policy refer to?
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When should an Affected Person consult the Company Secretary?
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Who has the ultimate responsibility for the Securities Dealing Policy in Access Bank Plc?
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What is the role of the Chief Conduct and Compliance Officer with regards to the policy?
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What is the responsibility of the Human Resources Group concerning the policy?
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Who is in charge of advising on the applicability and consequences of breach of the policy?
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What does the Securities Dealing Policy of Access Bank Plc exclude?
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How does the Policy treat breaches in terms of disciplinary actions?
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What is the main purpose of the Securities Dealing Policy mentioned in the text?
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Who are considered 'Affected Persons' according to the Securities Dealing Policy?
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What is the responsibility of Affected Persons regarding their dealings as per the text?
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What does the text mention as a key feature of the Policy's compliance standards?
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What is the purpose of the internal review mechanism within the Policy?
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Which regulatory bodies' provisions must Affected Persons comply with under this Securities Dealing Policy?
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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.
