On 30 January 2015, the ASX revised its Guidance Note 27 on trading policies in light of market developments since the last update in 2012.  Revised Guidance Note 27 makes it clear that the policy objective of trading policies is not only to minimise the risk of actual insider trading and market manipulation, but also to avoid the appearance of insider trading and outlines a number of additional points that ASX recommends be addressed in an ASX-listed entity’s trading policy.  ASX-listed entities should consider reassessing their trading policies in light of revised Guidance Note 27 to ascertain whether they adequately cover the ASX’s recommendations and if not, whether there is a sound justification for not doing so (noting that the minimum requirements for a trading policy contained in ASX Listing Rule 12.12 remain unchanged).

See G+T Corporate Advisory Alert on 4 February 2015 for further details and a checklist of the matters that should be covered in an ASX-listed entity’s trading policy.