Common use of Personal Account Dealing Policy Clause in Contracts

Personal Account Dealing Policy. All employees of DCCL are subject to a personal account dealing policy, which imposes certain restrictions, approval procedures and reporting requirements in relation to personal account dealing. The personal account dealing policy requires employees to disclose all personal dealing and in some cases receive prior approval for personal account transactions. Employees are required to avoid any personal account transactions that may place them in conflict with the interests of either clients or DCCL. Restricted lists Where DCCL is providing services to a particular person (E.g. a proposed acquirer of a company) or in relation to a particular person (eg the company proposed to be acquired), it may be appropriate that dealings in securities issued by one or more of such persons be restricted. DCCL maintains a restricted list. The restricted list provides the mechanism to communicate and apply any restrictions that may relate to certain business activities. Except where DCCL receives an unsolicited agency order in securities on the restricted list, no member of staff may, either for the firm’s DCCL account, a client’s account or their own personal account deal in any security for the time being included in the restricted list.