POC "Doverie" Български
Home News Contacts Questions and Answers Documents
05/02/2015
"PensionsEurope deeply concerned with developments in Bulgaria"
Pressrelease of the organization PensionsEurope
26/01/2015
Declaration by the International Federation of Pension Fund Administrators (FIAP)
05/03/2015
"Doverie above all"
Daniela Petkova for the "Forbes" magazine
02/02/2013
Solidarity pension systems will not disappear, but will undergo serious reforms
Interview with Daniela Petkova, Chair of the Management Board of PAC Doverie, published in Capital Weekly
Press release Vienna Insurance Group
Unit values for 20.10.2017: GPF "Doverie" - 1.73470 lv.; PPF "Doverie" - 1.77985 lv.; VPF "Doverie" - 1.84476 lv.
Rules regarding private transactions in financial instruments

                                                                                                   

Section I

General Provisions

 

Art. 1. These rules shall lay down the conditions under which the employees and the persons working for PAC Doverie AD (the Company) may effect private transactions in financial instruments on their own account or become beneficiaries of the yield from financial instruments through transactions effected by third parties.

 

Art. 2. The purpose of these rules is to eliminate any potential conflict of interest, as well as any conditions for the existence of an ostensible conflict of interests, between the professional activity connected with the investment of assets of the funds for supplementary pension insurance managed by the Company and of the company's own assets on the one hand and the private transactions in financial instruments of employees and persons working for the Company on the other, since any ostensible or real existence of such conflict of interests may cause serious damages to the reputation of the Company and affect its business in the long run.

 

Section II

Personal Range

 

Art. 3. (1) These rules shall refer to:

1. Employees of the Finance, Accounting and Investments (FAI) Department of the Company;

2. Members of the Board of Directors of the Company;

3. Members of the Investment Committee of the Company.

 

(2) These rules shall apply also to all persons working for the Company that may have inside information concerning the investment of the assets of the pension funds managed by the Company and of its own assets, entrusted to, or obtained by them in the course of discharge of their occupational or professional duties or incidentally.

 

(3) The persons referred to in paragraphs 1 and 2 shall sign declarations (Attachment 1) that they are acquainted with these rules and are obliged to adhere to them, within a period of three working days from the date of signing their employment agreement, their registration as members of the Board of Directors of the Company in the Trade Register, their appointment as members of the Investment Committee or from the date of obtaining  inside information concerning the investment of the assets of the pension funds managed by the Company and of its own assets.

 

Section III

Obligations of persons referred to in Article 3, paragraphs 1 and 2

 

Art. 4. Persons referred to in Art. 3, paragraphs 1 and 2  shall be obliged to:

1. treat equally and not allow conflicts of interests or creation of conditions for the existence of an ostensible conflict of interests between their private interests and their professional obligations connected with the investment of the assets of the funds for supplementary pension insurance managed by the Company and of the company's own assets.

 

2. Never make use of inside information entrusted to them or obtained in connection with their occupational duties related to the investment of the assets of the funds for supplementary pension insurance managed by the Company and of the company's own assets for their private benefit and to the detriment of the persons insured with the pension funds.

 

3. Shall not share inside information with third parties and shall take all reasonable measures to avoid leakage of such information either through documents, electronic or paper copies, or by conversations in the wrong place.

 

4. Effect private transactions in financial instruments and/or become beneficiaries to investment yields of financial instruments through third party transactions only under the conditions laid down in these Rules.

 

Art. 5.  Persons referred to in Art. 3, paragraphs 1 and 2  shall declare on annual basis for each calendar year the portfolios of financial instruments acquired on their own account or indirectly through third persons by signing a declaration (Attachment 2) which shall be submitted by the 15th day of January the following year together with the statement(s) of the investment intermediaries in custody of the declared assets.

 

Art. 6. Persons referred to in Art. 3, paragraphs 1 and 2  shall declare their intentions to effect a transaction in a financial instrument before the transaction is effected by phone, electronically or in any other manner, by signing a declaration (Attachment 3) containing the following details:

1. Type of transaction;

2. ISIN code of the financial instrument;

3. Name of the issuer;

4. Amount;

5. Investment intermediary;

 

Art. 7. Persons referred to in Art. 3, paragraphs 1 and 2  shall within 5 days from the date of settlement declare all transactions in financial instruments effected on their own account or transactions through third persons where they have become beneficiaries of yields from financial instruments, by signing a declaration (Attachment 4) containing the following details:

 

1. Type of transaction - sale, purchase;

2. ISIN code of the financial instrument;

3. Name of the issuer;

4. Quantity or par value purchased or sold

5. Unit price or 100 nominal value;

6. Transaction date;

7. Investment intermediary that intermediates the transaction;

8. Investment intermediary or custodian bank in custody of the financial instrument

 

Section IV

Obligations of the Specialized Internal Control Department

 

Art. 8. (1). The Specialized Internal Control Department of the Company shall prepare and keep a list of all persons referred to in Art. 3, paragraphs 1 and 2, the persons under Article 3, paragraph 2 being included in the list within a period of three days from the date of obtaining inside information and for a period not shorter than three months.

 

(2) The Specialized Internal Control Department of the Company shall update the list referred to in paragraph 1 based on information received from:

 

1. The Head of the Workforce and Salary Department - in the cases of Article 3, paragraph 1, item 1.

 

2. The Head of the Legal Department - in the cases of Article 3, paragraph 1, items 2 and 3.  

 

Art. 9. The Specialized Internal Control Department of the Company shall:

 

1. See to the fulfillment of the obligations on the part of the persons referred to in Art. 3, paragraphs 1 and 2;

2. Keep the declarations submitted by the persons under Art. 3, paragraphs 1 and 2 for a period of at least 10 years considered from the date of presentation of the declarations;

3. Report to the Chairperson of the Board of Directors of the Company all cases of non-fulfillment of obligations or violation of the present rules;

4. Watch closely for declared transactions, effected personally or through third parties that might arouse a real or ostensible conflict of interests between the private interests of the persons under Art. 3, paragraphs 1 and 2 and their duties in connection with investments in financial instruments of the assets of the funds for supplementary pension insurance managed by the Company and of the company's own assets and shall report promptly any such transaction to the Chairperson of the Board of Directors.

 

Art. 10. After receiving the report of the Specialized Internal Control Department the Chairperson of the Board of Directors of the Company undertakes all appropriate actions for the prevention or termination of any real or ostensible conflict of interests between the private interests of the persons under Art. 3, paragraphs 1 and 2 and their duties in connection with investments in financial instruments of the assets of the funds for supplementary pension insurance managed by the Company and of the company's own assets.

 

Transitional and final provisions

 

§ 1. These Rules are adopted by resolution of the Board of Directors of Doverie Pension Assurance Company, Minutes № 203 of October 28, 2008 and become effective from the same date.

 

§ 2. Within a period of five working days from the date these Rules become effective:

 

1. Persons referred to in Article 3, paragraphs 1 and 2 shall sign the declarations under Article 3, paragraph 3 and Articles 5, 6 and 7;

 

2. The Specialized Internal Control Department of the Company shall prepare the list referred to in Article 8, paragraph 1.

 


Ask your questions or make your comments here
Studiо ITTI
Web Based Solutions