Ann: Share Placement, page-45

The following should be brought to the attention of Management .
What constitutes inside trading:
Corporations Act 2001 (Cth)

1. Insider trading prohibition

What is insider trading?
The Corporations Act prohibits anyone in possession of “inside information” in relation to the Company’s securities, whether in their own capacity or as an agent for another, from:

• dealing in the securities; or
• communicating the information to others who might deal in the securities. “Inside information” means information that:
• is not generally available; and • if generally available, would be expected by a reasonable person to have a material effect on the price or value of securities in the Company (ie the information is “price-sensitive”). Annexure A to this Policy provides some further information as to when information might be considered “generally available” and “price-sensitive”.

Annexure A – “Information”, “generally available” and “price-sensitive” What is information and when is it considered “generally available”

• any actual or proposed change to the Company’s capital structure for example, a share issue;