Personal account dealing - excerpt of Compliance policy
Employees and connected persons are required to forward a copy of all contract notes of transactions in which they have been involved to the Compliance & Risk Manager immediately they are in receipt of such note. Employees have the option of requesting that their broker automatically sends the Compliance and Risk Team contract notes of transactions in which they have been involved.
In addition, neither the employee nor connected persons may deal on their own behalf ahead of a transaction in the same stock to be undertaken on behalf of the Fund (in other words, no "front running").
To support this, there should be no share dealing by individuals seven days before or after the Fund trades in the active global mandate, subject to exceptions (i.e. when the Fund trades quickly in response to a significant piece of news; in which case staff may legitimately have dealt in the same stocks within the previous seven days). Staff wishing to deal should check with the Active Global Equities Portfolio Manager, whether or not they can trade prior to doing so and if allowed, notify the Compliance and Risk Team.
The Compliance and Risk Team will check within the fourteen day window, all personal share dealings by staff against those of the Fund (taking into account those stocks which the Fund has traded on an exceptions basis). Additionally, the Fund will reconcile the contract notes of transactions against employees brought forward balance (i.e. statement of holdings) and their end of period position statement.
Generally, employees and connected persons must not deal in a security where they are in possession of non-public price sensitive information as defined by the Criminal Justice Act 1993. Employees should fully appraise themselves with the provisions of this Act.
When requested by the Compliance and Risk Team, the Fund requires employees to disclose their PAD and that of their connected persons.