Share Trading Policy

SHARE TRADING POLICY

Purpose

This share trading policy sets out the Company's policy regarding the trading in Company securities, which includes shares, options, warrants, debentures and any other security on issue from time to time. This policy is separate from and additional to the legal constraints imposed by the common law, the Corporations Act and ASX Listing Rules.

This policy applies to all Directors and employees of the Company and their associates (including spouses, children, family trusts and family companies) as well as contractors, consultants, advisers and auditors of the Company ("designated officers").

Requirements

It is illegal to trade in the Company's securities while in possession of unpublished price sensitive information concerning the Company. Under the Corporations Act a person with inside information must not, and must not procure another person, to deal in the securities of a body corporate or enter into an agreement to deal in the securities of a body corporate. Inside information is defined in the Corporations Act as information that:

• is not generally available; and
• if generally available, a reasonable person would expect it to have a
  material effect on the price or value of the securities of the body
  corporate.

General Prohibition on Insider Trading

All designated officers are prohibited from trading in the Company's securities while in the possession of unpublished price sensitive information concerning the company. In addition, while in possession of unpublished price sensitive information designated officers must not advise others to trade in the Company's securities or communicate the information to another person knowing that the person may use the information to trade in, or procure someone else to trade in, the Company's securities.

Unpublished price sensitive information is information regarding the Company, of which the market is not aware and that a reasonable person would expect to have a material effect on the price or value of the Company's securities, and includes:

• a proposed major acquisition or disposition;
• drill or exploration results;
• a significant business development or a proposed change in the nature of
  the Company's business;
• details of material contracts that are being negotiated by the Company;
• potential litigation that would have a substantial effect on the Company;
• a proposed change in the share capital structure of the Company;
• a proposed change in the Company's dividend policy; and
• a major change to the Board or senior management.

Restrictions on Short-Term Trading

The Company encourages Directors and employees to adopt a long-term attitude to their investment in the Company's securities. Consequently, Directors and employees may not engage in short-term or speculative trading of the Company's securities.

Permission to Trade

Directors, members of senior management and employees may trade in the Company's securities at other times so long as they are not in possession of any unpublished price sensitive information.

Exceptions

A person may trade in the Company's securities in the following circumstances:

• the Managing Director (or in the case of the Managing Director, another
  Director) approves the trade by a Director upon the director or Company
  Secretary satisfying the Managing Director that they do not possess
  unpublished price sensitive information about the company and a failure
  to trade in the company's securities would result in exceptional
  circumstances such as financial hardship;
• the Managing Director approves the trade by an employee upon the
  employee satisfying the Managing Director that they do not possess
  unpublished price sensitive information about the company and a failure
  to trade in the Company's securities would result in exceptional
  circumstances such as financial hardship;
• trade in a managed securities portfolio where the person is not in a
  position to influence choices in the portfolio; and
• where the trade results from a dividend reinvestment plan where the
  person has given ongoing instructions to reinvest dividends.

Notification of Proposed Trade in Company Securities

Managing Director

Prior to trading in (either buying or selling) the Company's securities, the Managing Director must notify the other Directors of his/her intention to trade and confirm that he/she is not in possession of any unpublished price sensitive information.

Non-Executive Directors

Prior to trading in (either buying or selling) the Company's securities, Non-Executive Directors must notify the Managing Director of their intention to trade and confirm that they are not in possession of any unpublished price sensitive information.

Employees

Prior to trading in (either buying or selling) the Company's securities, employees must notify the Managing Director of their intention to trade and confirm that they are not in possession of any unpublished price sensitive information.

The requirement to provide notice of an intention to trade in the Company's securities does not apply to the acquisition of securities through Director, officer or employee share or option plans. However, the requirement does apply to the trading of the securities once they have been acquired.

Notification of Trade in Company Securities

Directors must also notify the Company Secretary of any trade in the Company's securities as soon as practicable, but not later than 5 business days of such trade occurring 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.

The Company Secretary will maintain a register of all trades and holdings in Company securities by Directors.