Policy · Capital Markets & Securities — ECM/DCM and Disclosure
Securities trading policy (closed periods, clearance, exceptions)
ASX-compliant securities trading policy covering every matter Listing Rule 12.12 requires, plus insider trading, hedging, margin loans, director notifications and trading plans, with a clearance request form.
- Kind
- Policy. A policy or procedure for a firm or client.
- Where it applies
- Australia
- AI use
- Green AI can do most of the drafting. A lawyer still reviews the result.
- Law stated as at
- 17 October 2026
- Status
- Maintained. Checked on 17 October 2026 against the 5 authorities it cites, for Australia.
- Version
- 1
- Source
- Written for this library
When to use it
Use when an ASX-listed entity adopts or updates its trading policy, including before listing. Give the adopted policy to ASX for release, and give material changes within five business days. Not a substitute for advice on a particular proposed trade.
How AI may be used
AI may adapt this reviewed base policy to the company’s calendar and structure. Clearance decisions remain with the designated people.
AI may
- Populate closed periods from the company’s reporting calendar
- Draft a plain-language summary and FAQ for employees
- Check the adapted policy covers each Listing Rule 12.12 item
AI must not
- Must not give or refuse clearance to trade
- Must not assess whether a person holds inside information
- Must not process unannounced information when answering trading queries
The lawyer checks
- Closed periods and exceptions match the company’s reporting cycle and plans
- Clearance officers and escalation are named and workable
- Policy lodged with ASX and changes released within five business days
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Read the full text
The full text is for signed-in accounts. It is free. When you sign in you can:
- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
More in Capital Markets & Securities — ECM/DCM and Disclosure
- Continuous disclosure policy and disclosure committee charter
- Trading halt request letter to ASX
- Due diligence planning memorandum and verification protocol for a prospectus
- Checklist for AI-assisted verification of offer and disclosure documents
- Review checklist for AI-related statements in disclosure documents and annual reports ('AI washing')
All precedents for Capital Markets & Securities — ECM/DCM and Disclosure · Tasks and AI use in this area