Trading Policy

{{company_name}}

{{company_address}}

Phone: {{phone}} | Email: {{email}} | Web: {{website}}

Trading Policy

Trading Policy

{{company_name}}

{{company_address}}

Phone: {{phone}}

Email: {{email}}

Website: {{website}}

1. Introduction and Purpose

This Trading Policy (the “Policy”) sets forth the rules and procedures governing trading in securities, commodities, and other financial instruments by all employees, directors, and officers of {{company_name}} (the “Company”). The purpose of this Policy is to prevent insider trading, avoid conflicts of interest, maintain market integrity, and ensure compliance with all applicable laws and regulations in the Southern African business context.

2. Scope

This Policy applies to all employees, directors, and officers of the Company, as well as their immediate family members (spouse, children, and any other person sharing the same household) where such individuals make trading decisions based on information obtained from the employee. This Policy covers all transactions involving financial instruments, including but not limited to, shares, bonds, derivatives, and cryptocurrencies.

3. Definition of Inside Information

“Inside Information” means any information (a) that has not been made public; (b) that is specific or precise; and (c) which, if it were made public, would be likely to have a material effect on the price or value of any financial instrument. Examples include, but are not limited to, unannounced financial results, mergers and acquisitions, significant new contracts, changes in management, or material litigation.

4. Prohibition of Insider Trading

No employee, director, or officer shall, directly or indirectly, (a) trade in any financial instrument while in possession of Inside Information; (b) disclose Inside Information to any third party (tipping); or (c) advise or encourage any third party to trade based on Inside Information. This prohibition applies irrespective of whether the financial instrument is issued by the Company or another entity.

5. Pre-Clearance of Trades

All employees, directors, and officers must obtain pre-clearance from the Compliance Officer (or designated authority) prior to executing any trade in financial instruments at least {{number_of_days}} business days before the intended transaction date. The pre-clearance request must include details of the proposed transaction, including the type of instrument, quantity, and proposed transaction date. Approval for pre-clearance is valid for a period of {{validity_period_days}} days.

6. Blackout Periods

The Company may from time to time impose “Blackout Periods” during which certain individuals or all employees are prohibited from trading in specified financial instruments. These periods typically coincide with the release of financial results or other significant corporate events. Employees will be notified of Blackout Periods by {{communication_method}}.

7. Reporting Requirements

All employees, directors, and officers must report details of all their holdings and transactions in financial instruments to the Compliance Officer on a {{reporting_frequency}} basis, no later than {{reporting_deadline}} of the reporting period. This report should include the date of transaction, type of instrument, number of shares/units, price, and the identity of the broker/platform used.

8. Confidentiality

Employees are expected to maintain the confidentiality of all non-public information obtained during the course of their employment. This obligation extends beyond the termination of employment.

9. Consequences of Non-Compliance

Violation of this Policy may result in disciplinary action by the Company, up to and including termination of employment. Furthermore, individuals may face severe civil and criminal penalties under applicable laws, including substantial fines and imprisonment.

10. Policy Review

This Policy will be reviewed periodically, at least once every {{review_period_years}} years, by the Company’s legal and compliance departments to ensure its continued effectiveness and compliance with evolving legal and regulatory requirements. The last review was conducted on {{last_review_date}}.

Signature:

_________________________________________

Name: {{ signatory_name }}

Title: {{ signatory_title }}

Date: {{ date }}