Maintain insider trading policy + share trading window (listed entities)
ASX Listing Rule 12.12 requires written policy on directors + senior managers trading entity securities.
Who must comply
ASX-listed entities + their KMP.
What triggers it
Being listed.
When due
Continuous; trading windows enforced around price-sensitive announcements.
Evidence required
Published policy; trading window register; clearance approvals.
Max penalty
Insider trading criminal up to 15 years prison + 3× benefit; civil to financial-services max
Summary
ASX Listing Rule 12.12 requires listed entities to publish a written share trading policy covering directors + key management personnel. Must specify trading windows, blackout periods around results announcements, requirements for clearance, and prohibition of trading on inside information (Corporations Act s 1043A).
Enforced by
Source legislation
Entity types
Topics
Related obligations
- CWLTHApply 'if not why not' against ASX Corporate Governance Council Principles & Recommendations (4th ed)ASX-listed entities must disclose against 8 Principles + 38 Recommendations annually.
- CWLTHASX-listed entity board independence + composition (CGC Principle 2)ASX entities should have majority-independent boards + clear board charter.
- CWLTHComply with ASX continuous disclosure (Listing Rule 3.1)Listed entities must immediately disclose price-sensitive information to the market.
- CWLTHTwo-strikes rule on listed-company remuneration report (s 250R)If a remuneration report attracts 25%+ no votes twice running, a spill resolution must be considered.
Frequently asked questions
- Who must comply with insider trading policy + share trading window (listed entities)?
- ASX-listed entities + their KMP.
- What triggers insider trading policy + share trading window (listed entities)?
- Being listed.
- When is insider trading policy + share trading window (listed entities) due?
- Continuous; trading windows enforced around price-sensitive announcements.
- What is the maximum penalty for insider trading policy + share trading window (listed entities)?
- Insider trading criminal up to 15 years prison + 3× benefit; civil to financial-services max
- What evidence is required for insider trading policy + share trading window (listed entities)?
- Published policy; trading window register; clearance approvals.
Source: https://asx.com.au/listings/listing-rules-guidance. Rules Mate is not a law firm. Always verify against the live regulator source before acting.