Głowacki Law Firm

"Chinese walls" procedure under REMIT

 

 "Chinese walls" procedure under REMIT

 

1. Officers taking part in trading decisions with respect to electricity and the electricity-related products in the company departments, in which inside informationin the meaning of the Regulation No 1227/2011 of the European Parliament and of the Council of 25 October 2011 on wholesale energy market integrity and transparency (OJ L 326, 8.12.2011, p. 1 - REMIT) is generated (hereinafter referred as: "REMIT Restricted Persons") mustn't in parallel render services for other company's departments as well as for other companies of the company groupings, in particular, for the department responsible for the publication of REMIT inside information. 

 

2. The exception to the prohibition laid down in point 1 represents parallel services performed by the REMIT Restricted Persons for the department of other company from the company grouping, the sole activity of which is trading in electricity and electricity-related products. 

 

3. REMIT Restricted Persons should occupy premisses physically separated from other company's departments. Appropriate measures for controlling access to these departments should be applied..

 

4. REMIT Restricted Persons should only use the IT infrastructure, which safeguards that potential inside information is not circulated to unauthorised persons before its publication pursuant to REMIT. The same applies for internal procedures for the circulation of other forms of documentation in the company.

 

5. Company's inside information should also be protected from premature disclosure making use of procedures and physical measures in particular magnetic access cards, places of storage secured with keys available only for persons authorised, having due regard to their functions and tasks.

 

6. Conversations In public places or in other circumstances that cause the risk of inside information be unintentionally revealed are prohibited.

 

7. The responsibilty for monitoring of requirements imposed by the procedure is assigned to ..................... .

 

Officer responsible for IT matters is assigned with the responsibility to ensure IT systems in the company grant access to inside data to persons authorised due to their functions and tasks only. 

 

 

 

  

Last Updated on Friday, 20 September 2013 13:49
 

Search

TwitterFacebookLinkedin
Copyright © 2009 - 2019 Michal Glowacki. All rights reserved.
The materials contained on this website are for general information purposes only and are subject to the disclaimer