An Issuer must have in place from Admission a reasonable and effective dealing policy setting out the requirements and procedures for Directors' and Applicable Employees dealings in any of its Securities. At a minimum, an Issuer's dealing policy must set out the following:
(a) the Issuer's close periods during which Directors and Applicable Employees cannot deal;
(b) when a Director or Applicable Employee must obtain clearance to deal in the Admitted Securities of the Issuer;
(c) an appropriate person(s) within the Issuer to grant clearance requests;
(d) procedures for obtaining clearance for dealing;
(e) the appropriate time frame for a Director or Applicable Employee to deal once they have received clearance;
(f) how the Issuer will assess whether clearance to deal may be given; and
(g) procedures on how the Issuer will notify deals required to be made public under MAR.
Guidance:
Compliance with Rule 5.23 does not mean that an Issuer will have satisfied its obligations under Article
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