ABP.CCS.003 Securities Dealing Policy Overview

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18 Questions

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?

A person authorized to perform Company Secretary functions.

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

Dealing with securities not on a recognized exchange.

When should an Affected Person consult the Company Secretary?

Before undertaking any transaction involving the Bank's securities.

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

Board of Directors

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

Monitor adherence and observance

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

Keep records of breaches

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

Company Secretary

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

Investment in Unit Trusts

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

Applies sanctions without prejudice to statutory ones

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

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

Directors, Senior Management, Employees, and insiders of the Bank and its related companies

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

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

Providing a framework for seamless implementation

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

To measure compliance and effectiveness

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

CBN Code, SEC Rules, and Investments and Securities Act 2007

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.


  • "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.

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.

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