Prohibition of Trading During Restricted Periods

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The persons described as "primary insiders" who have access to inside information are not allowed to enter, during the so-called restricted periods, into any legal transactions, for their own account or for the account of a third party, which lead or might lead to the disposal of the Bank shares, derivative rights attached to the Bank shares or financial instruments related to such shares.

A restricted period is:

  • the time from the moment a primary insider receives inside information until such information is made public
  • in the case of an annual report – two months preceding the release of the annual report or, if shorter, the period between the end of the financial year and the release of the report
  • in the case of a semi-annual report – a month preceding the release of the report or, if shorter, the period between the end of a given six-month period and the release of the report
  • in the case of a quarterly report – two weeks preceding the release of the report or, if shorter, the period between the end of a given quarter and the publication of the report.

All the Bank's employees are notified of the opening and closing dates of restricted periods related to the publication of the Bank's periodic reports.

The prohibition of entering into transactions does not apply if the primary insider had no access to the financial data serving as the basis for the preparation of a given report.

A primary insider who undertakes investment activity during a restricted period is liable to administrative sanctions for violating the provisions of the Act on Trading in Financial Instruments, as well as to criminal sanctions.