Security Trading Policies
BBP's Security Trading Policies regulate the manner in which Directors of BBP entities, staff seconded to the Manager (Babcock & Brown Power Management Pty Limited) and senior management of the businesses wholly-owned by the BBP Group can trade in BBP securities and other financial products relating to the performance of BBP securities, such as options, warrants, contracts for differences etc. These Policies require that Directors, staff and management conduct their personal investment activity in a manner that is lawful and avoids conflicts of interests between their personal interests and the interests of BBP.
The specific objective of the Policies is to clearly specify the obligations and procedures for Directors, staff and management in relation to trading in BBP securities so as to minimise:
- any potential for breach of the prohibitions on insider trading contained in the Corporations Act; and
- the chance that misunderstandings or suspicions arise regarding Director, staff or management trading.
The Policies specify trading windows as the periods during which trading in BBP securities can occur. These trading windows will generally be the eight week periods following the release of BBP's full year or half year results, the eight week period following lodgement of BBP's Annual Report with the ASX and the offer period under any prospectus. However, these trading windows will not automatically be opened for these periods. A decision is made prior to each potential window to determine whether it is appropriate to open the trading window at that particular time. Also, following the opening of a trading window, the window may be closed at any earlier time if appropriate.
In accordance with the Security Trading Policies, trading in BBP securities is prohibited by Directors, staff and management despite a trading window being open if the relevant person is in possession of non-public price sensitive information regarding BBP.
The Policies also:
- prohibit Directors, staff and management communicating non-public price sensitive information to another person who might then trade in BBP securities, or procure another person to trade in BBP securities;
- provide an obligation on Directors, staff and management to seek to ensure that any third parties who come into possession of non-public price sensitive information preserve the confidentiality of that information and do not trade whilst in possession of that information;
- set out specific procedures to be followed by Directors and key management personnel in relation to pre-notification of an intention to trade in BBP securities during a trading window, as well as notification following confirmation of a trade;
- extend the restrictions on trading in BBP securities to the extent it is within a Director's, staff member's or manager's power to do so, to:
- a spouse or partner;
- other relevant family members;
- a company or trust over which the relevant person has influence or control;
- a trust where the relevant person is a beneficiary; and
- any other person over whom a Director, staff member or management has investment control or influence; and
- prohibit a Director, staff member or management trading in securities of other listed entities with which BBP may be dealing and where that person possesses non-public price sensitive information concerning the other listed entity.