# Planning Company Trades Well in Advance

> Conditions\, approvals\, and constraints for setting up pre\-committed trading plans\.

## 5. Planning company trades well in advance

A trading plan lets an insider publicly commit to future trades. It can help people whose work means they frequently hold UPSI, but the conditions are strict.

Trading cannot begin earlier than **120 calendar days after public disclosure**. Plans cannot overlap or facilitate market abuse. Each trade must specify its quantity or value, buy-or-sell direction, and a date or period of no more than five consecutive trading days.

The compliance officer must approve or reject a plan within **two trading days of receipt** and notify exchanges on approval day. The officer reviews compliance, may seek undertakings and monitors implementation.

Price limits are optional. They use the closing price on the day before submission: a buy ceiling may range from that price to 20% above it, and a sale floor from that price to 20% below it, rounded to the nearest numeral. A trade outside its chosen limit must not execute. Bonus issues and share splits can justify quantity and price-limit adjustments with compliance-officer approval and exchange notification.

Approved-plan trades need no separate pre-clearance and are exempt from ordinary trading-window restrictions. However, the September 2024 amendments removed the former exemption from contra-trade restrictions—rules against reversing a trade too quickly.

An approved plan is irrevocable and must be followed; trades outside its scope are prohibited. Specified deviation grounds include permanent incapacity, bankruptcy and the operation of law. Implementation cannot begin if UPSI held when the plan was formulated remains unpublished, even after the waiting period.

For full or partial non-implementation on recognised grounds, or because inadequate liquidity prevents execution, the insider must notify the compliance officer within **two trading days after the plan ends**, explaining why and supplying available supporting documents. The officer presents a recommendation at the next audit-committee meeting. The committee decides whether the failure was genuine; its decision goes to exchanges that day. Rejected explanations trigger conduct-code action.

This framework took effect on 24 September 2024. Footnote references to a six-month waiting period, minimum 12-month duration and plan-specific financial-results blackout describe older company rules. Mutual-fund plans retain different timing requirements.