Excert from ASIC / Corporations Act - for clarity
All listed entities should have in place a policy about share trading by directors and employees. Directors should encourage a workplace culture where the policies regarding trading in the company's securities and the prohibitions around insider trading are clearly understood, along with an appreciation of the risks that the policy is addressing. Such a policy should include appropriate 'closed periods' or 'blackouts' where trading is prohibited, any restrictions or exclusions on trading during other trading 'windows', and state the approvals required to be obtained before trading.
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