Insider trading toolbox

Toolbox

Our policies, standards and other resources

We have more in-depth Group policies, standards and guidance covering different aspects of confidential information. You can find links to them here.

In addition, there may be specific policies and procedures that apply where you work. Your manager can tell you about these. If you are unsure then always ask your manager.

(Please note: some of our resources are only available to Serco employees. In this case, you’ll need to log in to MySerco to access them. If you have problems accessing them, please request a copy from your manager.)

Governance, Legal and Assurance
One page statement defining Serco’s commitment to maintaining the best interests of all our stakeholders through creating and upholding an effective set of internal controls.

SMS-GSOP-G1-1 Insider Information and Share Dealing
Detailing processes to ensure that directors, employees and contractors do not place themselves under suspicion of abusing inside information that they may be thought to have.

SMS-GSOP-G1-2 Control and Escalation of Inside Information
Details internal controls to ensure that all directors, employees and contractors recognise potential inside information and understand controls and reporting requirements.

Share Dealing Code
Details restrictions on dealings in the securities of the Serco Group plc.

Definitions

The period of 30 days before release of relevant interim and full year results.

Any publicly traded or quoted shares or debt instruments of Serco Group plc (or of any of the Company’s subsidiaries or subsidiary undertakings) or derivatives or other financial instruments linked to any of them.

Anyone conducting any transaction on his or her own account or for the account of a third party, directly or indirectly, relating to Company Securities or on the price of related derivatives.

Information of a precise nature, which has not been made public, relating, directly or indirectly, to the Company or any Company Securities, and which, if it were made public, would be likely to have a significant effect on the price of any Company Securities.

The EU Market Abuse Regulation (596/2014).

Employees and other individuals who, due to their knowledge of specific information or a specific project may from time-to-time be notified that they will be classified as an Restricted Person until otherwise notified.

Means any employee considered by the Company to have ongoing access to Inside Information as part of their day-to-day role.

If you're a manager

Never act on or disclose inside information or encourage another person to deal in any company's shares on the basis of it, even if they do not directly profit.
Abide by the FCA's Disclosure Rules when dealing in Serco's stocks and shares. This includes specific restrictions if you have inside information.
Ensure those have potential access to insider information get written approval before trading in Company shares if you are an Employee Insider.