The Listed Companies Association Inc. is supportive of the overall proposals for law reform set out in the Bill, particularly with respect to insider trading laws, but has identified a number of areas where it considers clarification is required. The Association is however particularly concerned about the proposed removal of the exemption from the current insider trading regime for directors and officers of public issuers who trade in accordance with an approved procedure that complies with the Insider Trading (Approved Procedure for Company Officers) Notice 1996. The removal of the exemption will leave directors and officers of public issuers exposed to insider trading liability every time they trade securities they hold, and the Association urges the retention of the exemption.

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