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Engro Code of Conduct

This document outlines Engro Corporation's Insider Trading Policy. The key points are: 1) The policy applies to all transactions in Engro Corporation and its subsidiaries' securities by employees, directors, and others with access to non-public material information. 2) Insiders are prohibited from trading based on inside information and must report all trades within two days. They also cannot tip information to others. 3) Material non-public information is defined as information that could impact an investor's decision and includes financial results, mergers, investments, management changes, litigation, and supplier negotiations. 4) All related party transactions must be conducted at arm's length without compromising either party's interests.

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Ayesha Tariq
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32 views

Engro Code of Conduct

This document outlines Engro Corporation's Insider Trading Policy. The key points are: 1) The policy applies to all transactions in Engro Corporation and its subsidiaries' securities by employees, directors, and others with access to non-public material information. 2) Insiders are prohibited from trading based on inside information and must report all trades within two days. They also cannot tip information to others. 3) Material non-public information is defined as information that could impact an investor's decision and includes financial results, mergers, investments, management changes, litigation, and supplier negotiations. 4) All related party transactions must be conducted at arm's length without compromising either party's interests.

Uploaded by

Ayesha Tariq
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Insider Trading Policy i.

No Insider is permitted to buy or


sell, either directly or indirectly, in
Applicability of Policy such Engro Companies’ securities
This Policy applies to all transactions in the or to disclose that information to
listed equity securities of Engro Corporation any other person. Any confusion
and its listed subsidiaries (“Engro over the interpretation of this rule
Companies”) including ordinary shares, should be referred to either the
options for common shares including Chief Financial Officer or the
employee share option schemes and any other Company Secretary and;
securities that the Engro Companies may issue ii. All employees are restricted from
from time to time, such as preferred shares. It selling / buying or buying / selling
applies to all employees of Engro Corporation, any Engro Companies’ share within
and all members of the Board of Directors of a period of 6 months. However, this
Engro Corporation, who possess, receive, restriction does not apply to
come across or have access to Material Non employees who have acquired
public Information (as defined below) shares in an IPO of an Engro
regarding the Engro Companies. This group of Company, without any preferential
people, their spouses or lineal ascendants or allocation, or have acquired shares
descendants are referred to in this Policy as in the form of specie dividend or by
“Insiders.” This Policy also applies to any way of exercise of share options but
person who receives Material Non public will apply to those directors and
Information from any Insider (Tipping). employees who are restricted by the
Any person who possesses, receives, comes Companies Ordinance. Further, if an
across or has access to Material Non public employee or director violates this
Information regarding the Engro Companies is provision, then any gain that he/she
an Insider for so long as the information is not makes on such transactions will
publicly known. have to be surrendered to that
company.
Statement of the Policy
d) All trades of any Engro Companies’
The Policy, which governs Trading in securities by Insiders must be
Engro Companies’ Securities and reported within two days of the
“Tipping” states that; actual trade date to the Company
a) Subject to (b) and (c) below, trading in Secretary.
the Engro Companies securities (i.e., e) No Insider shall disclose or “tip”
purchase or sale of shares, and the any Material Non public
exercise of share options granted to Information to any other person nor
certain of its employees) is permitted shall such Insider make
throughout the year by all employees, recommendations or express
directors and officers. opinions on the basis of Material
b) No trading in the securities of Engro Non public Information as to
Corporation is permitted for directors, and trading in any of the Engro
all employees within the Closed Period of Companies’ securities.
Engro Corporation. Moreover, employees It is emphasized that any failure to observe
are also restricted from trading in securities this Policy may expose the director, or
of other Engro Companies within the employee, as well as the Engro Companies,
closed period of such companies. to legal liability including penal
c) Notwithstanding paragraph (a) above, consequences, under applicable securities
laws and therefore

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would be a violation of Engro  Projection of production / sales
Corporation’s policy on Business Ethics. performance;
Furthermore, employees who violate this  Results of product developments /
Policy shall also be subject to disciplinary new product announcements,
action by Engro Corporation which may business partnership and other major
include ineligibility for future participation investments;
in the Engro Companies equity incentive  News of a pending or proposed
plans and / or termination of employment. merger, acquisition or joint venture;
 News of planned disposition of a
Material Non Public Information subsidiary, or major investment /
It is not possible to define all categories divestiture;
of material information. However  New equity or debt offerings or
information should be regarded as significant changes to existing
material if there is a reasonable profiles;
likelihood that it would be considered  Impending bankruptcy or financial
important to a reasonable investor in liquidity problems;
making an investment decision regarding  Major changes in senior
the purchase or sale of any of the Engro management;
Companies’ securities. The final decision  Significant litigation exposure and
with regard to materiality of information development thereto; and
shall rest with the Management  Knowledge of negotiations of supply
Committee of Engro Corporation. terms / new arrangements with critical
Material information which has not been raw material suppliers.
disclosed to the general public is defined
as Material Non Public Information and Transactions / Contracts with
may include, but is not restricted to: related parties
 Financial results; It is the policy of the Company that all
 Projections of future earnings or related party transactions involving goods,
losses; services and transfer of tangible and
intangible assets will carried out at arms
length without compromising the business
interest of either party.

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