TRADING POLICY

• Guidelines for Dealing in Securities
  
  
• Information Policy
  

Guidelines for Dealing in Securities

The Guidelines for Dealing in Securities Policy adopted by the Board prohibits trading in shares by a director, officer or employee 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 or employee 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 and employees must receive clearance from the Executive Director before he may buy or sell shares

Directors, officers and employees 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 SBIL’s securities and to correct any material mistake or misinformation in the market. SBIL 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.

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