Regal Partners Adopts Revised Securities Trading Policy Effective 12 November 2026

Mukul

12 November 2026 04:24 PM AEDT

Regal Partners Adopts Revised Securities Trading Policy Effective 12 November 2026

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Regal Partners Limited (ASX:RPL) has disclosed a revised Securities Trading Policy, which took effect on 12 November 2026, replacing the company's previous Securities Trading Policy in accordance with ASX Listing Rule 12.10.

Key Points

The revised Securities Trading Policy takes effect from 12 November 2026 and replaces the previous policy.
The policy was released in accordance with ASX Listing Rule 12.10 and was authorised for release by Company Secretary Alexandra Rose.
The policy applies to Relevant Persons and Associates, covering when they must not deal in Company Securities or securities of another entity.
Insider trading is described in the policy as a criminal offence under section 1043A of the Corporations Act, punishable by substantial fines, imprisonment, or both, and may also attract civil penalties.

Policy Scope and Application

According to the filing, the revised Securities Trading Policy applies in conjunction with the Group's other policies regarding trading in securities. It outlines when Relevant Persons and Associates must not deal in Company Securities, when they must not deal in securities of another entity, and certain limited exceptions to restrictions on dealing in Company Securities. The filing states that if the policy conflicts with any law, regulatory requirement, contractual obligation or other Group policy, the more stringent standard applies. Relevant Persons are also directed to the Group's Employee Securities Trading Policy for details of approvals required before dealing in securities of other entities.

Definition of Inside Information Under the Policy

The policy defines Inside Information as information that is not generally available and that, if it were generally available, would or would be likely to influence persons who normally invest in securities in deciding whether to acquire or dispose of the relevant securities. The filing notes that Inside Information need not relate only to the Company — it could also concern a customer, supplier, an entity into which the Company has invested, or a party with whom the Company is discussing future opportunities or negotiating a significant transaction. Examples listed in the policy include changes in funds under management, proposed capital structure changes, proposed dividends, material acquisitions, and changes to the Board or key management personnel.

Definition of Dealing and Insider Trading Consequences

The policy outlines that dealing in securities includes applying for, acquiring or disposing of securities, or entering into an agreement to do so. Specific forms of dealing in Company Securities listed in the policy include buying or selling on-market or off-market, granting or disposing of a beneficial interest, exercising options or rights, acquiring securities under equity incentive plans, accepting entitlements under rights issues or share purchase plans, accepting takeover bid offers, and entering into derivatives. The filing states that insider trading may result in criminal penalties including substantial fines and imprisonment, and that civil penalties and compensation orders may also be imposed by a court.

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