It is illegal to trade in the Company’s securities while in possession of unpublished price sensitive information concerning the Company.

This Policy applies to all the Directors of the Company and all the employees of the Company.

The time for any Director or employee to buy or sell Company securities is limited
to the four (4) week period from the:
(a) date of the Company’s Annual General Meeting;
(b) release of the quarterly results announcement to the Australia Stock
Exchange (ASX);
(c) release of the half yearly results announcement to the ASX;
(d) release of the preliminary final results announcement to the ASX; or
(e) release of a disclosure document offering securities in the Company.

The Company may at its discretion vary this rule in relation to a particular period
by general announcement to all employees either before or during the period.

However, if a Director or employee of the Company is in possession of price
sensitive information which is not generally available to the market, then he or
she must not deal in the Company’s securities at any time.

No short-term trading in the Company’s securities
Directors and employees should never engage in short-term trading of the
Company’s securities except for the exercise of options where the shares will be
sold shortly thereafter.

Securities in other companies
Buying and selling securities of other companies with which the Company may
be dealing is prohibited where an individual possesses information which is not
generally available to the market and is ‘price sensitive’. For example, where an
individual is aware that the Company is about to sign a major agreement with
another company, they should not buy securities in either the Company or the

Directors must also notify the Company Secretary of any trade in the Company’s securities within 5 days of such trade 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.