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INTERNAL DEALING PROCEDURE Release: 1st July2014 1 Section I INTRODUCTION 1. FOREWORD 1.1 The Internal Dealing Procedure (the Procedure) relates to the subject of internal dealing, i.e. the transparency
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Who needs internal dealing procedure:

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Organizations that are publicly traded or regulated by financial authorities often require an internal dealing procedure. This helps mitigate the risk of insider trading and ensures compliance with relevant laws and regulations.
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Employees or individuals who have access to sensitive or confidential information about the organization, its securities, or market-related activities may be required to follow an internal dealing procedure.
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Directors, officers, executives, and other key personnel who make decisions that may impact the organization's financial performance or share value may also be subject to internal dealing procedures to maintain transparency and integrity within the organization.

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Internal dealing procedure refers to a set of rules and guidelines that govern the buying and selling of securities by individuals within an organization.
Individuals who are considered insiders or have access to non-public information are typically required to file internal dealing procedure.
Internal dealing procedure can be filled out by providing details about the securities being bought or sold, the date of the transaction, and any other relevant information.
The purpose of internal dealing procedure is to prevent insider trading and ensure transparency in the buying and selling of securities within an organization.
Information such as the name of the individual making the transaction, the type of security being traded, the date of the transaction, and the price of the security must be reported on internal dealing procedure.
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