Trinity Mirror


Share Dealing Policy

The Company has adopted the Model Code, as published by the UK Listing Authority in the Listing Rules.

Copies of the code are available from the Company Secretary's office and the Company Secretarial staff will offer help and guidance on interpretation of the code.

Anyone who is deemed by the Company to be an "employee insider" is required to seek consent before they enter into any transaction concerning the Company's shares. This would obviously normally be either buying or selling shares in the Company but would also include the exercising of options or granting a charge over shares. It covers all circumstances where an employee is other than entirely passive. It would not cover a straight gift to an employee or the exercise of SAYE options at the end of the contract period when they reach full maturity. It does however apply to the sale of those shares.

PLC Directors require the consent of the Chairman of the Company or in his absence the Senior Independent Director. The Chairman requires the consent of the Chief Executive and the Senior Independent Director. Other employee insiders require the consent of either the Chief Executive or the Company Secretary.

The Company Secretary's office retains the Request to Deal form which needs to be completed by the employee insider before consent is given. This form requires the person seeking consent to confirm that they are not in possession of any "inside information".

Consent, when given, will only be valid for 48 hours per the Model Code. It is the responsibility of the person seeking consent to ensure that the person giving consent will be available at the time they wish to deal.