Code of Conduct Africa (open file)-nw - Airtel Africa

Insider TradingOBJECTIVETo ensure that the investor community at large is well informed andthat their concerns and queries are appropriately addressedTo ensure that undue advantage is not taken by those who haveinformation not available to all investorsCODEEmployees should not effect any transaction in the shares of anyBharti company, or another company involved with Bharti usingmaterial non public information about those companiesSensitive information [pg. 41] is something that could have areasonable bearing on the movement of share priceAlso see Insider Trading PolicyDOsDONTsEnsure that any sensitive document, be it in hard copy or inelectronic copy, is kept in a secure placeThose having access to sensitive information should be awareof their responsibility and refuse to share any detail with anycolleague who does not need this information, in the normalcourse of his or her dutiesDon’t discuss details regarding performance plans, potentialshare price movements, etc., with anyone outside theCompany, not even with friends and familyDo not disclose or discuss with any person during the ‘silentperiod,’ commencing from the end of the financial quarter, untilthe date of announcement of results of a listed Bharti companyDo not make any forward-looking statements about theCompany24