TRADING POLICY

Securities Trading Policy

The Securities Trading Policy adopted by the Board prohibits trading in shares by a director, officer, employee, relevant contractors and consultants during certain blackout periods (in particular, prior to release of interim or annual results) except in exceptional circumstances and subject to procedures set out in the Guidelines.

Outside of these blackout periods, a director, officer, employee, relevant contractors and consultants must first obtain clearance in accordance with the Guidelines before trading in shares. For example:

  • a director must receive clearance from the Chairman before he may buy or sell shares
  • if the Chairman wishes to buy or sell shares he must first obtain clearance from the Executive Director
  • other officers, employees, relevant contractors and consultants must receive clearance from the Executive Director before he may buy or sell shares

Directors, officers, employees, relevant contractors and consultants must observe their obligations under the Corporations Act not to buy or sell shares if in possession of price sensitive non-public information and that they do not communicate price sensitive non-public information to any person who is likely to buy or sell shares or communicate such information to another party.

 

Information Policy

The Company is a “disclosing entity” for the purposes of Part 1.2A of the Corporations Act. As such, the Company has an Information Policy. The purpose of this Information Policy is to set out the procedure for:

  • protecting confidential information from unauthorised disclosure;
  • identifying material price sensitive information and reporting it to the Company Secretary for review;
  • ensuring the Group achieves best practice in complying with its continuous disclosure obligations under the Corporations Act and ASX Listing Rules; and
  • ensuring the Group and individual officers do not contravene the Corporations Act or ASX Listing Rules.

The Group has obligations under the Corporations Act and ASX Listing Rules to keep the market fully informed of information which may have a material effect on the price or value of SPL’s securities and to correct any material mistake or misinformation in the market. SPL discharges these obligations by releasing information to the ASX in the form of an ASX release or disclosure in other relevant documents (e.g. the Annual Report).

The Group recognises that the maintenance of confidentiality is also of paramount importance to the Company both to protect its trade secrets and to prevent any false market for the Company’s shares from developing.

All relevant information provided to ASX in compliance with the continuous disclosure requirements of the Corporations Act and ASX listing rules is promptly posted on the Company’s web site under Investor Relations.

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