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Where Representatives would be entering into transactions which limit the economic risk of a Representatives security holding in the Company, including arrangements which limit the economic risk of participating in unvested entitlements under any equity based remuneration schemes.  


Please note that, even if it is outside of a Precluded Period, Representatives must not deal in the Company’s securities if they are in possession of inside information.
Trading which is not subject to this policy
The following dealings in securities by Representatives is excluded from this policy, unless at the time of the dealing the Representative is in possession of market sensitive information that is not generally available:
transfers of securities of the Company already held in a superannuation fund or other saving scheme in which the Representative is a beneficiary;
an investment in, or trading in units of, a fund or other scheme (other than a scheme only investing in the securities of the Company) where the assets of the fund or other scheme are invested at the discretion of a third party;

Company Charter & PoliciesDealings by Related Parties

    A Representative must use reasonable endeavours to ensure that his or her immediate family members, company, trust or entity which is controlled by the Representative or an immediate family member of the Representative (each a
  • Board CharterRelated Party
  • ) are aware of this Policy. If a Representative may not deal in Company securities, he or she must take all reasonable and necessary steps to prevent any dealing in Company securities by Related Parties unless the Representative has complied with this Policy on behalf of that Related Party in respect of the proposed dealing.
  • Code of Conduct
  •  
  • Share Trading Policy
  • No hedging of unvested entitlements
  • Audit & Risk Committee
  • A Representative must not enter into transactions which would have the effect of hedging or transferring the risk of any fluctuation in the value of:
  • Risk Management Policy
any unvested entitlement to Company securities; or
Company securities which are vested but still subject to a holding lock.

Contact Us

Phone +61 (8)  8132 9111 
contactus@lcke.com.auThis would include acquiring derivatives or options in relation to Company securities.

An unvested entitlement in Company securities would include equity rights which are still subject to time and/or performance hurdles.

 
No short term dealing or short selling

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Notwithstanding any provision in this Policy, a Representative must not:
engage in short term dealing in Company securities within a 3 month period, but does not include the sale of Company securities after they have been acquired through the conversion of a security, for example the exercise of an option, or in accordance with Company employee incentive schemes;
short sell Company securities; or
knowingly allow their Company securities to be used for short selling.
 

Changes in Directors’ Holdings
Directors must advise the Company Secretary of changes to their security holdings in the Company and any of its related bodies corporate within two business days of the change.