Share Trading Policy
Babcock & Brown has implemented a Share Trading Policy which regulates the manner in which Directors and employees can buy or sell shares in the Company and other publicly traded shares in companies which may be affected by the activities of the Group, and requires that they conduct their personal investment activities in a manner that is lawful and avoids conflicts between their own interests and those of the Group and its clients. The policy is specifically designed to raise awareness and minimise any potential for breach of the prohibitions on insider trading contained in the Corporations Act.
The policy specifies trading windows as the periods during which trading in securities issued by Babcock & Brown and any fund managed by a member of the Group can occur. These trading windows will generally be the eight week period following the release of the Group’s full year or half year results, the one month period following Babcock & Brown’s Annual General Meeting, and the offer period under any prospectus. Trading is prohibited despite a window being open if the relevant person is in possession of non-public price sensitive information regarding the Group. The Board may authorise the opening of trading windows at other times. Key Management Personnel of the Company are required to notify the Company Secretary (who in turn notifies the Chairman) of any proposed trading by them in securities issued by the Company and the details of any completed trades.
Certain shareholders of Babcock & Brown (primarily employees) who received their shares in connection with the IPO of Babcock & Brown hold their shares subject to voluntary escrow restrictions. After any escrow expires the relevant shareholder must give notice of any intended sale to the Company Secretary. This notice will authorise (but not oblige) the Company to arrange the sale of the shares on behalf of the holder within certain price parameters. This policy is intended to give the Group the opportunity to ensure that an orderly market is maintained.