Common use of Personal Account Dealing (“PAD”) and Outside Clause in Contracts

Personal Account Dealing (“PAD”) and Outside. Business Activity CESL has a policy on PAD and the rules are signed off as understood by all relevant employees regardless of their position within CESL. The PAD procedures require pre-approval by the relevant business head and notification to CESL’s Compliance Officer and all staff are required to annually attest to PAD holdings and annually report any outside business investment activity to the Compliance Officer. All staff are regularly reminded of the PAD rules.