237. The board should –
(a) disclose to the public, on an urgent basis, information on material changes in its
financial condition or operations;
(b) if it is a listed company, prohibit the dealing in its shares by directors, officers and
other selected employees for a designated period preceding the announcement of its
financial results or during any other period considered sensitive, and have regard to
the listing requirements of the Zimbabwe Stock Exchange rules and any other
applicable rules and legislation in respect of dealings of directors;
(c) prohibit insider trading and abusive self-dealing and ensure that members of the
Board and key executives disclose to the Board whether they, directly, indirectly or on
behalf of third parties, have a material interest in any transaction or matter directly
affecting the company;
(d) review transactions with related parties (including internal group transactions) in
order to assess risk and ensure that the transactions are subject to appropriate
restrictions (e.g. by requiring that such transactions be conducted on arm’s -length
terms) and that corporate or business resources of the organization are not
misappropriated or misapplied; and
(e) formulate and document a formal written conflict of interest policy and an objective
compliance process for implementing that policy.

238. The chief audit executive should have a standing invitation to attend executive or management meetings.

239. The chief audit executive should be on the same level with other heads of departments within the company.

• According to the NATIONAL CODE ON CORPORATE GOVERNANCE ZIMBABWE