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The Star Entertainment Group Limited (ASX:SGR) has announced an updated Securities Trading Policy effective 26 June 2026, following approval by its board and in accordance with ASX Listing Rule 12.10. The revised policy, now at version 7.1, outlines refreshed trading obligations and restrictions for all personnel, directors, and designated individuals within the group. This update occurs as The Star faces increased regulatory and governance scrutiny, emphasizing the importance of robust internal controls and compliance frameworks to investors. The policy is accessible on The Star's corporate governance webpage and was authorised for release by Group Company Secretary Eirene Garnsey.<\/p> <\/div>
Key Points<\/h3>
- Company: The Star Entertainment Group Limited (ASX:SGR)<\/li>
- Board approval granted for updated Securities Trading Policy (version 7.1), effective 26 June 2026<\/li>
- Policy applies to all directors, officers, employees, contractors, and consultants of SGR and its subsidiaries<\/li>
- Designated Persons—including directors, executives, and direct reports—are subject to stricter trading restrictions, including mandatory clearance and blackout periods<\/li>
- Prohibitions on Margin Lending<\/a>, Short Selling<\/a>, and hedging of SGR securities by Designated Persons are introduced or reaffirmed<\/li>
- Next scheduled policy review is set for 31 May 2028<\/li>
- Investors should monitor forthcoming governance disclosures and regulatory developments impacting SGR's operating environment<\/li>
<\/ul>
<\/div>
Board Endorses Version 7.1 of Securities Trading Policy Effective 26 June 2026<\/h2>
The Star Entertainment Group’s board officially approved the updated Securities Trading Policy on 26 June 2026. The company disclosed this update to the market on 1 July 2026, complying with ASX Listing Rule 12.10, which mandates notification to the exchange upon amendments to trading policies. The updated policy, designated version 7.1, is overseen by the Group Company Secretary, underscoring the critical role of compliance within The Star’s governance framework.<\/p>
The policy’s next planned review date is 31 May 2028, indicating the board does not foresee near-term changes under typical circumstances. However, the document allows for updates at any time, and the recent effective date—just days before the public announcement—demonstrates the board’s prompt action to modernize the framework. The updated policy is publicly available on The Star’s corporate governance site at starentertainmentgroup.com.au.<\/p>
Scope: Comprehensive Coverage of SGR Personnel, Subsidiaries, and Associates<\/h2>
The revised policy applies broadly, encompassing all directors, officers, employees, contractors, and consultants of SGR, its subsidiaries, and associated entities—collectively termed "SGR Personnel." This includes individuals engaged on fixed-term or fixed-task contracts and employees of incorporated contractors or consultants, extending obligations beyond the direct workforce.<\/p>
Additionally, obligations extend to "Associates" of Designated Persons, including spouses, de-facto partners, dependent children, family trusts, family companies, self-managed Superannuation<\/a> funds, and other entities controlled by a Designated Person. The policy also notes that joint venture partners or their employees and contractors may be considered Associates in relevant situations. This broad definition aims to prevent circumvention of trading restrictions through connected parties.<\/p>
Designated Persons Include Directors, Executives, and Key Financial Staff<\/h2>
A key aspect of the updated policy is the formal designation of "Designated Persons," who face more stringent obligations than general SGR personnel. This category includes all executive and non-executive directors of SGR and its subsidiaries, independent Compliance Committee members, executives reporting directly to the Managing Director and CEO, and their direct reports.<\/p>
It also covers executive assistants to directors and executives, members of the financial reporting team, and others designated by the board, Chair, CEO, or Company Secretary. This provision enables swift inclusion of employees involved in strategically sensitive or market-moving matters, such as transaction negotiations, regulatory submissions, or restructurings. Including the financial reporting team aligns with best practices recognizing their access to advance Earnings<\/a> or Balance Sheet<\/a> information and the associated Insider Trading<\/a> risk.<\/p>
Blackout Periods and Clearance Requirements for Designated Persons<\/h2>
The policy prohibits Designated Persons from trading SGR securities during specified Blackout Periods. While exact blackout dates are not detailed in the update, such periods typically coincide with the lead-up to half-year and full-year financial results and other times when material non-public information may be present. These measures provide a structural safeguard against insider trading risks.<\/p>
Outside these blackout windows, Designated Persons must obtain written clearance before trading. The policy outlines the clearance application process, specifying who can grant clearance and the timeframe for executing trades once approved. Crucially, clearance does not override the absolute prohibition on trading when in possession of inside information, a point emphasized explicitly in the policy.<\/p>
Unwavering Insider Trading Prohibition and Its Relation to Clearance<\/h2>
The updated policy firmly states that insider trading is prohibited at all times, regardless of clearance status or trading windows. If an individual holds inside information, they must not trade even outside blackout periods or if clearance has been granted. Inside information is defined as non-public information likely to materially affect SGR securities’ price or value if disclosed. Personnel uncertain about holding inside information are instructed to abstain from trading. This conservative stance aligns with the Corporations Act 2001 (Cth) insider trading provisions referenced within the policy.<\/p>
Ban on Margin Lending, Short Selling, and Hedging Transactions<\/h2>
The policy explicitly forbids Designated Persons from engaging in margin lending arrangements, short selling, or hedging involving SGR securities. These prohibitions comply with ASX guidance and reflect expectations that senior personnel maintain economic interests aligned with shareholders.<\/p>
Hedging is particularly scrutinized as it can mask true economic exposure to the company’s performance. The ban signals the board’s expectation that Designated Persons retain genuine economic alignment. The short selling prohibition prevents insiders from profiting from share price declines, while the margin lending restriction mitigates risks associated with leveraged trading pressures.<\/p>
Exemptions and Trades Not Requiring Clearance<\/h2>
Certain transactions are exempt from clearance requirements even for Designated Persons. Although the update does not detail these exclusions, they typically include vesting of performance rights under incentive plans without timing discretion, participation in standard Dividend reinvestment<\/a> plans, or trades under pre-established, non-discretionary trading plans.<\/p>
These exemptions recognize that not all transactions involve discretionary trading that could trigger insider trading risks. Nonetheless, the absolute insider trading prohibition remains paramount; individuals holding inside information must refrain from trading regardless of exemption status. This layered approach ensures legal obligations under the Corporations Act prevail over procedural exceptions.<\/p>
Compliance Oversight and ASX Disclosure Responsibilities<\/h2>
The policy includes compliance monitoring provisions and outlines the company’s duty to notify the ASX of relevant trading by key management personnel, in line with ASX Listing Rules<\/a> 3.19A and Appendices 3X, 3Y, and 3Z. The Group Company Secretary administers the policy, handling clearance applications and monitoring adherence.<\/p>
Violations of the policy or insider trading laws are treated with severity. The policy prohibits any breaches by SGR personnel or their Associates and references criminal Liability<\/a> under Part 7.10 of the Corporations Act, underscoring significant legal and reputational consequences. The board intends the policy to be applied in both letter and spirit.<\/p>
Governance Significance for Investors Amid Regulatory Scrutiny<\/h2>
The Star Entertainment Group has been under intense regulatory and public scrutiny, particularly regarding its casino licence suitability in New South Wales and Queensland. Against this backdrop, the updated Securities Trading Policy serves both symbolic and practical purposes, demonstrating active board and management oversight of internal governance frameworks—a factor likely considered by regulators, institutional investors, and other Stakeholders<\/a> assessing the group’s remediation progress.<\/p>
While the update does not represent a material commercial or financial guidance change, it visibly reflects governance operations during a critical period in The Star’s history. The company disclosed no changes to financial forecasts, operational guidance, or strategic direction in this announcement. Investors may focus on upcoming regulatory decisions, licence outcomes, or financial restructuring events as more significant near-term catalysts. The immediate share price impact of this governance update was not evident from public information.<\/p>
Looking Ahead: Scheduled Review in May 2028 and Continued Compliance<\/h2>
With the Securities Trading Policy now effective, the next formal review is scheduled for 31 May 2028. Until then, it governs the trading conduct of all SGR personnel and their Associates, with Designated Persons subject to enhanced clearance and blackout requirements. The Group Company Secretary remains responsible for policy administration and any interim updates required by circumstances.<\/p>
SGR personnel are advised to familiarize themselves with version 7.1, especially those classified as Designated Persons. For Market Participants<\/a> and investors, the key message is that The Star’s board has reaffirmed its commitment to a comprehensive framework designed to uphold market integrity and manage insider trading risks. Further governance disclosures and regulatory updates will be important developments to monitor in The Star’s ongoing narrative.<\/p>
Board Endorses Version 7.1 of Securities Trading Policy Effective 26 June 2026<\/h2>
The Star Entertainment Group’s board officially approved the updated Securities Trading Policy on 26 June 2026. The company disclosed this update to the market on 1 July 2026, complying with ASX Listing Rule 12.10, which mandates notification to the exchange upon amendments to trading policies. The updated policy, designated version 7.1, is overseen by the Group Company Secretary, underscoring the critical role of compliance within The Star’s governance framework.<\/p>
The policy’s next planned review date is 31 May 2028, indicating the board does not foresee near-term changes under typical circumstances. However, the document allows for updates at any time, and the recent effective date—just days before the public announcement—demonstrates the board’s prompt action to modernize the framework. The updated policy is publicly available on The Star’s corporate governance site at starentertainmentgroup.com.au.<\/p>
Scope: Comprehensive Coverage of SGR Personnel, Subsidiaries, and Associates<\/h2>
The revised policy applies broadly, encompassing all directors, officers, employees, contractors, and consultants of SGR, its subsidiaries, and associated entities—collectively termed "SGR Personnel." This includes individuals engaged on fixed-term or fixed-task contracts and employees of incorporated contractors or consultants, extending obligations beyond the direct workforce.<\/p>
Additionally, obligations extend to "Associates" of Designated Persons, including spouses, de-facto partners, dependent children, family trusts, family companies, self-managed Superannuation<\/a> funds, and other entities controlled by a Designated Person. The policy also notes that joint venture partners or their employees and contractors may be considered Associates in relevant situations. This broad definition aims to prevent circumvention of trading restrictions through connected parties.<\/p>
A key aspect of the updated policy is the formal designation of "Designated Persons," who face more stringent obligations than general SGR personnel. This category includes all executive and non-executive directors of SGR and its subsidiaries, independent Compliance Committee members, executives reporting directly to the Managing Director and CEO, and their direct reports.<\/p>
It also covers executive assistants to directors and executives, members of the financial reporting team, and others designated by the board, Chair, CEO, or Company Secretary. This provision enables swift inclusion of employees involved in strategically sensitive or market-moving matters, such as transaction negotiations, regulatory submissions, or restructurings. Including the financial reporting team aligns with best practices recognizing their access to advance Earnings<\/a> or Balance Sheet<\/a> information and the associated Insider Trading<\/a> risk.<\/p>
The policy prohibits Designated Persons from trading SGR securities during specified Blackout Periods. While exact blackout dates are not detailed in the update, such periods typically coincide with the lead-up to half-year and full-year financial results and other times when material non-public information may be present. These measures provide a structural safeguard against insider trading risks.<\/p>
Outside these blackout windows, Designated Persons must obtain written clearance before trading. The policy outlines the clearance application process, specifying who can grant clearance and the timeframe for executing trades once approved. Crucially, clearance does not override the absolute prohibition on trading when in possession of inside information, a point emphasized explicitly in the policy.<\/p>
The updated policy firmly states that insider trading is prohibited at all times, regardless of clearance status or trading windows. If an individual holds inside information, they must not trade even outside blackout periods or if clearance has been granted. Inside information is defined as non-public information likely to materially affect SGR securities’ price or value if disclosed. Personnel uncertain about holding inside information are instructed to abstain from trading. This conservative stance aligns with the Corporations Act 2001 (Cth) insider trading provisions referenced within the policy.<\/p>
The policy explicitly forbids Designated Persons from engaging in margin lending arrangements, short selling, or hedging involving SGR securities. These prohibitions comply with ASX guidance and reflect expectations that senior personnel maintain economic interests aligned with shareholders.<\/p>
Hedging is particularly scrutinized as it can mask true economic exposure to the company’s performance. The ban signals the board’s expectation that Designated Persons retain genuine economic alignment. The short selling prohibition prevents insiders from profiting from share price declines, while the margin lending restriction mitigates risks associated with leveraged trading pressures.<\/p>
Certain transactions are exempt from clearance requirements even for Designated Persons. Although the update does not detail these exclusions, they typically include vesting of performance rights under incentive plans without timing discretion, participation in standard Dividend reinvestment<\/a> plans, or trades under pre-established, non-discretionary trading plans.<\/p>
These exemptions recognize that not all transactions involve discretionary trading that could trigger insider trading risks. Nonetheless, the absolute insider trading prohibition remains paramount; individuals holding inside information must refrain from trading regardless of exemption status. This layered approach ensures legal obligations under the Corporations Act prevail over procedural exceptions.<\/p>
The policy includes compliance monitoring provisions and outlines the company’s duty to notify the ASX of relevant trading by key management personnel, in line with ASX Listing Rules<\/a> 3.19A and Appendices 3X, 3Y, and 3Z. The Group Company Secretary administers the policy, handling clearance applications and monitoring adherence.<\/p>
Violations of the policy or insider trading laws are treated with severity. The policy prohibits any breaches by SGR personnel or their Associates and references criminal Liability<\/a> under Part 7.10 of the Corporations Act, underscoring significant legal and reputational consequences. The board intends the policy to be applied in both letter and spirit.<\/p>
The Star Entertainment Group has been under intense regulatory and public scrutiny, particularly regarding its casino licence suitability in New South Wales and Queensland. Against this backdrop, the updated Securities Trading Policy serves both symbolic and practical purposes, demonstrating active board and management oversight of internal governance frameworks—a factor likely considered by regulators, institutional investors, and other Stakeholders<\/a> assessing the group’s remediation progress.<\/p>
While the update does not represent a material commercial or financial guidance change, it visibly reflects governance operations during a critical period in The Star’s history. The company disclosed no changes to financial forecasts, operational guidance, or strategic direction in this announcement. Investors may focus on upcoming regulatory decisions, licence outcomes, or financial restructuring events as more significant near-term catalysts. The immediate share price impact of this governance update was not evident from public information.<\/p>
With the Securities Trading Policy now effective, the next formal review is scheduled for 31 May 2028. Until then, it governs the trading conduct of all SGR personnel and their Associates, with Designated Persons subject to enhanced clearance and blackout requirements. The Group Company Secretary remains responsible for policy administration and any interim updates required by circumstances.<\/p>
SGR personnel are advised to familiarize themselves with version 7.1, especially those classified as Designated Persons. For Market Participants<\/a> and investors, the key message is that The Star’s board has reaffirmed its commitment to a comprehensive framework designed to uphold market integrity and manage insider trading risks. Further governance disclosures and regulatory updates will be important developments to monitor in The Star’s ongoing narrative.<\/p>
Designated Persons Include Directors, Executives, and Key Financial Staff<\/h2>
Blackout Periods and Clearance Requirements for Designated Persons<\/h2>
Unwavering Insider Trading Prohibition and Its Relation to Clearance<\/h2>
Ban on Margin Lending, Short Selling, and Hedging Transactions<\/h2>
Exemptions and Trades Not Requiring Clearance<\/h2>
Compliance Oversight and ASX Disclosure Responsibilities<\/h2>
Governance Significance for Investors Amid Regulatory Scrutiny<\/h2>
Looking Ahead: Scheduled Review in May 2028 and Continued Compliance<\/h2>
