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>> SHARE TRADING

The Constitution of the Company permits directors and officers to acquire shares in the Company.

In accordance with the provisions of the Corporations Act and the Listing Rules of the Australian Stock Exchange Limited, directors must advise the Company and the ASX of any transactions they conducted in securities in the Company.

The ASG Insider Trading Policy prohibits the buying or selling of Company securities at any time by any director, officer, executive, contractor, consultant or employee (“Insiders”) who possesses price-sensitive information about the company that is not available to investors and the stock market generally.

This prohibition applies regardless of how the person learns of the information. This policy is intended to enhance investor confidence and help to minimise the suspicion of trading by company directors, executive managers or employees who may be in possession of price sensitive information which has not been publicly released.

As a broad principle, Insiders are permitted to trade Company shares in the 30-day period immediately following the release of ASG’s half yearly and annual results and in the 30-day period immediately following the Company’s Annual General Meeting. However, possession of price-sensitive information during these periods would negate the right of individuals to engage in trading during these periods.

Individuals who have price-sensitive information not generally available to investors and the stock market:

• Must not trade in any securities of the Company.
• Must not engage any other person or entity to trade in the Company’s securities.
• Must not allow the price-sensitive information to be disclosed to another person who may use the information for improper trading purposes.
• Must not communicate inside information to any other individual who works within the ASG Group except on a “need to know” basis.

If an individual liaises with stock brokers, industry analysts or business journalists and the like regarding the business activities of ASG, they must not disclose to them any inside information about ASG, or confirm any analysis, the confirmation of which would constitute price-sensitive and non-public information.