becoming a substantial holder notice, page-10

Hi Bermuda ! I wouldn't read to much in to that insider trading announcement ! plenty of others are doing the same ? Maybe ASX have issued them all with a reporting ( best practice notice )

GBZ also had one today ! see below.

GBM RESOURCES LIMITED
ABN 91 124 752 745
SHARE TRADING POLICY

This share trading policy sets out the Companys policy regarding the trading in the Company?s securities. This policy is separate from and additional to the legal constraints imposed by the common law, the Corporations Act and the ASX Listing Rules.

This policy applies to Relevant Persons including all Directors, Key Management Personnel and Employees of the Company, and their related parties.

It is illegal to trade in the Companys securities while in possession of unpublished price sensitive information concerning the Company. Under the Corporations Act a person with inside information must not, and must not procure another person, to deal in the securities of a body corporate or enter into an agreement to deal in the securities of a body corporate. Inside information is defined in the Corporations Act as information that:


is not generally available; and

if it were generally available, a reasonable person would expect it to have a material effect on the price or value of the securities of the body corporate.
General Prohibition on Insider Trading

All Relevant Persons are prohibited from trading in the Companys securities while in possession of unpublished price sensitive information concerning the Company. In addition, while in possession of unpublished price sensitive information Relevant Persons must not advise others to trade in the Companys securities or communicate the information to another person knowing that the person may use the information to trade in, or procure someone else to trade in, the Company?s securities.

Unpublished price sensitive information is information which the market is not aware and that a reasonable person would expect to have a material effect on the price or value of the Companys securities, and includes:

a proposed major acquisition or disposition;

a significant business development or a proposed change in the nature of the Companys business;

reserve and resource compilation;

exploration drilling results;

details of material contracts that are being negotiated by the Company;

potential litigation that would have a substantial effect on the Company;

a proposed change to the share capital structure of the Company; and


a major change to the Board or senior management.
Restrictions on Short‐Term Trading
The Company encourages Directors, other Key Management Personnel and Employees to adopt a long‐term attitude to their investment in the Companys securities. Consequently, Relevant Persons should not engage in short;term or speculative trading of the Companys securities.

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Trading in Derivative Products
Relevant Persons are prohibited from trading outside Trading Windows, as defined by this policy, in financial products issued or created over or in respect of the entitys securities.

Guidelines for Dealing in Securities
Clearance Procedures Prior to Trading
All Relevant Persons must receive clearance for the proposed trading of the Companys securities on by informing and receiving written approval from the Chairman (or if unavailable, the Managing Director) prior to undertaking a transaction
Clearance to trade will apply for a period of 5 business days from the communication to the Relevant Person of the clearance to trade, and management will endeavour to provide its written acknowledgment within 2 business days of the request being submitted by the Relevant Person.
Trading Window
Relevant Persons may trade in the Company?s securities on ASX in the period of 10 business days commencing 24 hours following:

the holding of the Annual General Meeting or any other General Meeting;

the announcement of Annual or Half‐Year results;

the announcement of Quarterly Reports; and

any other public announcement on ASX.
Except where the Relevant Person is in possession of unpublished price sensitive information or the Company is in possession of unpublished price sensitive information and notifies the Relevant Person they may not trade during all or part of the trading window.
Outside Trading Window
Outside of the trading window, all Relevant Persons must receive clearance for the proposed trading of the Company?s securities on by informing and receiving written approval from the Chairman (or if unavailable, the Managing Director) prior to undertaking a transaction.
Clearance to trade in the Company?s securities outside of the defined Trading Windows may be granted in exceptional circumstances at the discretion of the Chairman (or if unavailable, the Managing Director). Exceptional circumstances would include, but not be limited to cases of severe financial hardship, where court orders exist or other overriding legal or statutory circumstance requiring the sale or transfer of the securities.
Clearance to trade outside a trading window will apply for a period of 5 business days from the communication to the Relevant Person of the clearance to trade
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Trades excluded from the Share Trading Policy
The requirement to provide notice of an intention to trade in the Company?s securities does not apply to the acquisition of securities through the GBM Resources Limited Option Plan, GBM Resources Limited Performance Rights Plan, Share Purchase Plans and Entitlement Offers. However the requirement does apply to the trading of the securities once they have been acquired.
The Share Trading policy does not apply where there is no change in beneficial interest in the securities.
The Share Trading Policy does not apply to the disposal of securities by acceptance of takeover offers.
Breach of Policy
Breaches of this policy will be subject to disciplinary action, which may include termination of employment. If Relevant Persons are unsure of whether they are able to trade in the Company?s securities at a particular time, they are advised to consult with the Chairman, Managing Director or Company Secretary.
Notification of trade in Company Securities
Directors must also notify the Company Secretary of any trade in the Company?s securities within 3 business days of such trade occurring so that the Company Secretary can comply with the ASX Listing Rule 3.19A requirement to notify the ASX of any change in a notifiable interest held by a Director.
The Appendix 3Y ? Change of Directors Interest Notice lodged with the ASX must provide the following information:

whether the trading occurred outside a Trading Window, when prior written clearance was required;

whether clearance was provided to allow the Trade to proceed; and

on what date clearance was provided if granted