Insider Trading Policy (UK) by Study Academy
Insider Trading Policy defines and prohibits market abuse through trading or disclosure of non-public, price-sensitive information. Developed by the Study Academy Workplace Compliance team, specialists in accredited UK compliance training.
Insider Trading Policy (UK, 2025 Edition)
Purpose
This Policy prohibits the use of inside information for personal gain or to the detriment of the market, clients or the organisation. It sets out rules for dealing in securities and handling price-sensitive information.
Scope
Applies to all directors, officers, employees, contractors and consultants who may have access to inside information relating to the organisation or another entity.
Definition of Inside Information
Inside information is information of a precise nature, which is not public, which relates directly or indirectly to an issuer or financial instrument, and which, if made public, would be likely to have a significant effect on the price of those financial instruments.
Prohibited Conduct
Dealing in securities while in possession of inside information.
Recommending or inducing another person to deal based on inside information.
Unlawful disclosure of inside information.
Legislative Framework
UK Market Abuse Regulation (UK MAR)
Criminal Justice Act 1993
Financial Services and Markets Act 2000
Insider Lists
The organisation shall maintain insider lists identifying all persons with access to inside information. Such persons shall be notified of their obligations and trading restrictions.
Clearance to Deal
Persons discharging managerial responsibilities (PDMRs) and other designated persons must obtain written clearance before dealing in the organisation’s securities during closed periods or when in possession of sensitive information.
Sanctions
Breaches of this Policy may result in disciplinary action up to and including dismissal, civil penalties and criminal prosecution.
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England & Wales note
This version is drafted for England & Wales. Scotland and Northern Ireland differ on some points — for example notice periods and tribunal procedure. Tell GitLaw where you hire and it adjusts the draft.
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