Market Abuse & Insider Information Policy

This policy applies to all personnel of Applique and to any other person who, by virtue of their engagement with Applique, may receive inside information. It reflects the requirements of the EU Market Abuse Regulation (MAR) and equivalent local regimes.

• Insider dealing in financial instruments while in possession of inside information
• Unlawful disclosure of inside information
• Market manipulation, including the dissemination of misleading information
• Recommending or inducing another person to engage in any of the above

Applique operates information barriers and need-to-know principles in mandates that may involve inside information. Insider lists are maintained where required by law.

Personnel are subject to personal account dealing rules, including pre-clearance and restricted-list requirements, designed to prevent actual or perceived misuse of inside information.

Personnel receive periodic training on market abuse. Suspected breaches must be reported immediately through the whistleblowing channel or directly to compliance.