On Monday 2 November 2026, the compliance officer of Kowloon Bay Asset Management Ltd gives Ms Lau, a relevant person, written permission to buy shares in a listed company. The firm has no pending or recent fund orders in the stock. She places her order on Wednesday 11 November. What is the position?
Under para 2.1.1(b), relevant persons need prior written permission for personal account dealing from the compliance officer or another person designated by senior management, and the permission should be valid for no more than five trading days. Working: 2 to 6 November are five trading days (no Hong Kong public holiday falls in that week), so 11 November is the eighth trading day and the permission has lapsed. The 30-day figure is the minimum holding period in para 2.1.1(c), not the life of a permission; ten trading days is invented; and a fund order is a separate constraint, not the only way permission ends. Source: SFC Fund Manager Code of Conduct (October 2024), para 2.1.1(b)-(c) (as at October 2026).
Mixing up the two staff-dealing numbers: permission lasts at most five trading days; the minimum holding period is 30 days.
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