Check a securities trading policy against the minimum content rules

Key facts

Human involvement
YellowClose supervision
How AI is used
From the policy, mark each item in Listing Rule 12.12 as present or missing, and record whether the policy has been given to the market announcements office. If a material change has taken effect, count five business days from that date. Do not write replacement clauses.
What the lawyer must review
The lawyer decides what the policy should say, writes any change, and authorises the release.
Written for / version
US

Open a jurisdiction version of this task to see which instruments apply: US

Who does what

Who does what
RoleWhat they do
AssistanceFrom the policy, mark each item in Listing Rule 12.12 as present or missing, and record whether the policy has been given to the market announcements office. If a material change has taken effect, count five business days from that date. Do not write replacement clauses.
LawyerSet the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Checklist

  1. Confirm the policy contains each of rules 12.12.1 to 12.12.5. A missing item is a gap, not a clause for the tool to write.
  2. Confirm the policy was given to the market announcements office.
  3. A material change must be given within five business days of the change taking effect, not of the board paper.
  4. The lawyer reads the Chapter 19 definitions of closed period, key management personnel and prohibited period before the gaps are treated as closed.

Sources

These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.

Guidance Note 27 was not opened. The minimum content is taken from Chapter 12.

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