Page 69 - CCL AR 2017 Final

Insider

Trading Policy

Cherat Cement has taken definitive steps in ensuring that all
employees, officers, members of the Board and all such relevant
persons follow strict guidelines while trading in the shares of the
Company. The Insider Trading Policy codifies the Company’s
standards on trading and enabling the trading of securities of the
Company or other publicly-traded companies while in possession
of material non-public information.

The general guidelines within the policy state that:

i. No trading in the securities of the Company is permitted for
directors and all employees who are “Executives” as defined in
the Code of Corporate Governance, within the Closed Periods
announced by the Company.

ii. No insider may purchase or sell any Company’s security while
in possession of material non-public information about the
Company, its customers, suppliers, consultants or other
companies with which the Company has contractual
relationships or may be negotiating transactions.

iii. No insider who knows of any material non-public information
about the Company may communicate that information to any
other person, including family and friends.

iv. In addition, no insider may purchase or sell any security of any
other company, whether or not issued by the Company, while
in possession of material non-public information about that
company that was obtained in the course of his or her
involvement with the Company in the way of conducting
official business. No insider who knows of any such material
non-public information may communicate that information to
any other person, including family and friends.

The Company’s Responsibility to Disclose Inside Information

The Company’s responsibility, in case of inside information made
known to a third party, shall be to ensure that in such case the
knowledge is given full public disclosure or if such information
still needs to be kept non-public then the Company must ensure
that the third party, is placed under legal obligation to maintain
confidentiality.

67
Annual
Report 2017