SOR 1.64% 6.0¢ strategic elements limited

I think the only specified closed (blackout) periods are when it...

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    I think the only specified closed (blackout) periods are when it comes to announcing HY and FY results - the blackout starts from 1 Jan and 1 July, and is in effect until those results are announced. So that’s like 6-8 weeks later.

    Aside from that, I think things are a little grey. Such blackout periods are decided by the company itself and are specified in their trading policy. Essentially directors cannot trade when they are in possession of market-sensitive knowledge. That is knowledge that would give them a perceived trading advantage. So, blackout periods are common for miners (for example) before they announce quarterly exploration reports, and for companies that might announce trading updates (and changes to guidance). The problem is that what is considered ‘market-sensitive’ can be open to interpretation.

    I don't know what SOR's trading policy states, but certainly it would not be in the spirit of the Listing Rules if a Director bought a bunch of shares then announced a significant update a few days later. But with that said, plenty of Directors have been pushing the boundaries on these rules for years.
 
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