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Corporate Communications, Disclosure and Insider Trading Policy

Corporate Communications, Disclosure and Insider Trading Policy. . Preamble Public Disclosure Insider Trading Confidentiality. . Preamble Public Disclosure Insider Trading Confidentiality. . Purpose of Policy. The objectives of this policy are:.

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Corporate Communications, Disclosure and Insider Trading Policy

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  1. Corporate Communications, Disclosure and Insider Trading Policy 

  2. Preamble Public Disclosure Insider Trading Confidentiality 

  3. Preamble Public Disclosure Insider Trading Confidentiality 

  4. Purpose of Policy The objectives of this policy are: • Ensure consistent standards and procedures for corporate communications • Ensure timely compliance with regulations • Ensure directors, officers and employees of SIRTEX understand corporate obligations 

  5. Application of Policy The communication policy applies to: • Directors • Officers • Employees • All other individuals authorised to speak on “behalf of SIRTEX” (contractors, agents, distributors, proctors, consultants etc) 

  6. Non-Compliance Failure to comply with this policy may result in: • Internal disciplinary action • Civil penalties • Criminal penalties • Termination of employment without notice 

  7. Preamble Public Disclosure Insider Trading Confidentiality 

  8. Public Disclosure - Definition Public Disclosure: It is against the law and this policy for any person acting on behalf of SIRTEX to selectively disclosematerial and non-public information to securities professionals or to stockholders of SIRTEX under circumstances where it is reasonably foreseeable that the stockholder may be likely to trade on the basis of such information, unless the information is simultaneously disclosed to the public . 

  9. Public Disclosure – Who is acting on behalf of SIRTEX The only individuals authorised to represent SIRTEX in its dealings with securities professionals and stockholders, including institutional investors, are • Chairman • CEO • CFO • Company secretary • Others designated in writing by the CEO and/or the Company secretary (the “Authorised Company Representatives”). 

  10. Public Disclosure – What is material information Material information is any information that a reasonable investor would consider important in making an investment decision. This includes but is not limited to: • Financials • Change in corporate objectives • Product discovery • FDA activities • Legal action • Change in management 

  11. Public Disclosure – What is non-public information Material information is “non-public” if it has not been disseminated in a manner making it available to investors generally. 

  12. Public Disclosure of non-material information We must organise and facilitate dissemination of non-material information Speaking engagements and presentations by employees of SIRTEX must be approved in advance Directors, officers or employees who are not authorised company representatives must not respond to inquiries from the investment community, the media or others, unless specifically asked to do so by an authorised company representatives. 

  13. Public Disclosure - Reporting of Violations If a director, officer or employee of SIRTEX becomes aware that non-public material information has been selectively disclosed by a person acting on behalf of SIRTEX, the Chairman, CEO, CFO, director, company secretary should be contacted immediately. 

  14. Preamble Public Disclosure Insider Trading Confidentiality 

  15. Insider Trading Policies All employees, officers and directors of SIRTEX who have knowledge of undisclosed material information relating to SIRTEX or its business are expressly prohibited from buying or selling, exercising options to buy or sell or tipping someone else to buy or sell (or not to buy or sell), securities of SIRTEX unless and until such information has been publicly disclosed and disseminated. 

  16. Insider Trading Policies This prohibition applies to family members and others living in your household who gain access to or become aware of inside information. All employees, officers & directors of SIRTEX are also responsible for compliance within their own environment. 

  17. Insider Trading Policies - Blackout Periods There are three scheduled permitted trading periods each year. These follow bi-annual disclosures of earnings, and AGM. The trading periods are as follows: • The trading window is defined as the period two days after and no later than 45 days after the company has released its annual or half yearly results to the market, or held its AGM. • Anytime outside these trading windows is to be considered a black-out period 

  18. Preamble Public Disclosure Insider Trading Confidentiality 

  19. Confidentiality All directors, officers and employees of SIRTEX who know material information relating to SIRTEX that has not been communicated to the public are prohibited from communicating that information internally or externally to anyone else, except as may be necessary in the course of business to persons who “need-to-know” the information in order to perform his or her responsibilities at SIRTEX. 

  20. Confidentiality The following procedures should be observed at all times: • Documents and files containing confidential information should be kept in a safe place to which access is restricted to individuals on a need-to-know basis. • Confidential matters should not be discussed in places where the discussion may be overheard, such as elevators, hallways, restaurants, airplanes or taxis. • Use of analogue wireless telephones or other analogue wireless devices to discuss confidential matters should be avoided, where possible. 

  21. Confidentiality • Confidential documents should not be read or displayed in public places and should not be discarded where others can retrieve them. • Employees must ensure that they maintain the confidentiality of information in their possession outside of the office as well as inside of the office. • Transmission of documents by electronic means, such as by fax or directly from one computer to another, should be made only where it is reasonable to believe that the transmission can be made and received under secure conditions. 

  22. Confidentiality • Unnecessary copying of confidential documents should be avoided and documents containing confidential information should be promptly removed from conference rooms and work areas after meetings have concluded. • Extra copies of confidential documents should be shredded or otherwise destroyed. • Access to confidential electronic data should be restricted through the use of passwords. 

  23. Preamble Public Disclosure Insider Trading Confidentiality 

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