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Under the Sonic Securities Trading Policy, all Sonic Healthcare employees are prohibited from buying or selling Sonic Healthcare securities at any time they are aware of any material price sensitive information that has not been made public, and are reminded of the laws against "insider trading". Prohibitions also apply to financial instruments related to Sonic's securities and to trading in the securities of other entities using information obtained through employment with Sonic.
In addition to the general prohibitions, certain “Designated Officers”, including all directors and senior executives (and specified related parties), are also prohibited from trading in periods other than in 8 week windows following the release of half year and full year results, and 2 week periods following Sonic Healthcare’s provision to the market at any time of definitive guidance regarding the next annual result to be released. Exceptions to this prohibition can be approved by the Chair (for other directors) or the Managing Director (for all other Designated Officers) in circumstances of financial hardship. All trading by Designated Officers must be notfied to the Company Secretary. In addition, the Managing Director and Finance Director are required to obtain approval from the Chairman before selling any shares.
Designated Officers are prohibited from entering into transactions in products which limit the economic risk of participating in unvested entitlements under any equity based remuneration schemes. Designated Officers will forfeit their equity reward should they be found to be in breach of this policy.
All Sonic Healthcare securities dealings by directors are promptly notified to the Australian Securities Exchange (ASX) in accordance with Sonic’s Continuous Disclosure obligations.