Securities Trading Policy » Synergy Metals Limited » Corporate Governance

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Securities Trading Policy

The Company’s securities trading policy is designed to ensure that directors, officers, employees and contractors (herein referred to as ‘Relevant Persons’) comply with all legal restrictions and prevent insider trading with respect to trading in the Company’s securities.

The policy restricts Relevant Persons from trading on material unpublished price sensitive information until it has been released to the market and adequate time has been given for this to be reflected in the securities’ price.

In particular, the Company:

  • must comply with the requirements of the ASX Listing Rules and Corporations Act 2001;
  • must receive prior notification from Relevant Persons of their intention to deal in the Company’s securities; and
  • prohibits short term trading by Relevant Persons in the Company’s securities.

Trading Policy

Relevant Persons of the Company should not trade in the Company’s securities when he or she is in possession of price sensitive (“inside”) information that is not generally available to the market.

Non Trading Period

Relevant Persons are likely to be in possession of unpublished price sensitive information concerning the Company by virtue of their position within the management company.

Those persons are restricted from dealing in the Company’s securities in the two week period immediately before release to the ASX of:

  1. the Company’s financial results; or
  2. the holding of a shareholders meeting.

Relevant Persons are restricted from dealing in the Company’s securities in the first two business days following release to the ASX of all price sensitive information.

Trading in Company’s Securities

Relevant Persons can only deal in the Company’s securities after having first obtained prior written clearance from the Chairman or Managing Director and must notify the Company Secretary when a trade has occurred.

A Director must notify the Company Secretary within 3 business days after dealing in securities of the Company to enable the Company Secretary to inform the ASX of the details of trading in the Company’s securities.

Trading not subject to Policy

This Policy does not restrict a purchase of securities or the exercise of an option or right under an approved employee incentive scheme; a transfer of securities where there is no change in beneficial interest; trading by a Relevant Person who is a trustee but not a beneficiary of a trust; or trading under a rights issue, security purchase plan or distribution reinvestment plan.

Margin Loan disclosure

Where a Relevant Person has a margin loan which is secured in whole or in part by the Company’s securities, that person or entity must provide details of the margin loan and the number of securities being secured by the loan to the Company Secretary within 14 days of the margin loan being obtained.