Pinnacle updates personal trading policy for enhanced compliance

Pinnacle Investment Management Group Limited (ASX: PNI) has updated its personal trading policy, effective December 2025. This revision was submitted to the ASX and is also available on the company’s website. The policy, owned by risk and compliance, applies to all directors, employees, consultants, and contractors of the group and their associates, with provisions for derogations by the board in specific cases.

The updated policy outlines stringent rules against insider trading, defining inside information as non-public information that would materially affect security prices if generally available. Personnel are prohibited from trading PNI securities during two fixed prohibited periods: from 8 am on July 1 to 5 pm on the first full trading day after the announcement of annual financial results, and from 8 am on January 1 to 5 pm on the first full trading day after the announcement of half-yearly financial results. Exceptional circumstances for trading during these periods require prior written approval from the chair of the board or the chair of the ACRMC.

All personnel must seek prior approval for trading PNI securities, providing details such as trading direction, quantity, and proposed price, and confirming they are not in possession of inside information. Approved trades are valid for five business days. The policy also introduces a minimum holding period of two months for PNI securities, with exceptions for involuntary corporate actions. Breaches of the policy are considered serious misconduct, potentially leading to disciplinary action up to summary dismissal. The policy was approved by the Audit, Compliance and Risk Management Committee, and was signed off in December 2025.