Ann: Change of Director's Interest Notice, page-6

I'm unsure if this is exactly true. ptongwon.

ASX Listing Rules & Insider Trading (Key Points)

1. Insider Trading is Prohibited at All Times

Under Australian law (Corporations Act 2001), it is illegal for a director to:

• Buy or sell company securities while in possession of material nonpublicinformation.

• Information is considered “material” if a reasonable person would expect it to affect the share price.

Even before a formal announcement, if a director knows somethingprice-sensitive, they must not trade.

⏳ 2. No Trading Before a Significant Announcement

• A director must not buy shares before a significant (market-sensitive) announcement unlessthe information is already public.

• ASX doesn’t impose a specific cooling-off orwaiting period, but best practice is:

  • Wait until after the announcement is released to the market (via ASX platform).

  • Wait at least 24–48 hours post-announcement forthe market to digest the news.

️ 3. Blackout Periods (Trading Windows) – Common in ASX Companies

Most ASX-listed companies adopt their own Share Trading Policies, which:

• Prohibit directors from trading during “blackout periods”, usually:

  • 30 days before financial results (half-year and full-year).

  • Sometimes before other price-sensitive events (e.g. AGM, capital raising).

• Allow trading in open windows, e.g.:

  • For a few weeks, from 24–48 hours after results are announced.

4. Director Disclosure Obligations

• Under ASX Listing Rule 3.19A ands205G of the Corporations Act, a director must notify the ASX within 5 business daysafter a change in their holdings.

• The company must lodge this notice (Appendix 3Y) with the ASX.

✅ Summary: Director Buying Before Announcement (ASX)

	Scenario	Legal?	Risk Level
1	Buying while knowing ofpending good news	❌ Illegal	High
2	Buying during the blackout period	❌ Against policy	High
3	Buying just before the announcement (but no inside info)	⚠️ Risky/Discouraged	Moderate to High
4	Buying after the announcement, during the open window	✅ Allowed	Low