Ann: Appendix 3Y - Andrew Seaton, page-74

Trading during the Prohibited Period

Securities Trading Policy - 4 September 2020.pdf Period.

An interesting topic.

STX Securities Trading Policy covers all shareholders and employees, not just executives.

See 5.1 (3)

In general, trading by company personnel can take place only outside the Prohibited Period. set by the company. But there are exceptions.

See 4.3

Insider trading within the Prohibited Period without prior exemption is a criminal offence. It is punishable by substantial fines or imprisonment or both under the Act.

IMO, at the very least, a Chair and a non-executive Director who cosigns an approval should, and they have been found to have acted contrary to the rules, have their employment terminated immediately.

Your thoughts?





It's fairly tight. No cavalier approach allowed here.

Well, fellows, this is your company, what are you going to do about the current situation.

Are you going to seek an explanation, which would in all probability, justify the position taken and put all speculation to rest, or just cop it sweet and let it fester.

The ball is in your court. Good luck.

All IMO. J L.