Ann: Appendix 3Y - C Smith-Gander, page-6

You do have that wrong.

The relationship between the timing of director on-market purchases and price sensitive announcements is commonly misunderstood.

There are restrictions on director purchases immediately prior to periodic disclosures that are under a company’s control (annual, half-yearly or quarterly reports), but the company does not know when price sensitive information such as the receipt of a significant purchase order from a client will arise.

ASX Listing Rule 3.1 states:
“Once an entity is or becomes aware of any information concerning it that a reasonable person would expect to have a material effect on the price or value of the entity’s securities the entity must immediately tell ASX that information.”

Considering this rule it becomes obvious that a director cannot time a share transaction prior to a price sensitive announcement, because the announcement cannot be delayed to allow that to occur.

As an example, on 13/11/15 G Rezos made an on-market purchase. Three days later the Company received its first purchase order for Alexiflam FR+DWR, requiring its immediate announcement