Securities Trading Policy

This policy applies to directors, officers, contractors, consultants and employees and their associates (Representatives) of Leigh Creek Energy Limited (Company) when dealing with securities in the Company. The purpose of this policy is to prevent Representatives from using information gained through their position in the Company. Ultimately, however, it is the responsibility of the person to ensure that none of his or her dealings could constitute insider trading.

This Policy outlines:

Risk Management Policy
• when Representatives may deal in Company Securities;
Management of risk is a primary objective of Leigh Creek Energy Limited (“the Company”) in all its business activities. The Company is committed to ensuring that its culture, processes and structures facilitate realisation of the Company’s business objectives, including potential opportunities, while its system of risk oversight, management and internal control are appropriate.
• when Representatives are permitted to deal in Company Securities; and
The key areas of risk identified by the Board are:
• procedures to reduce the risk of insider trading.
Operational risk

 

Indigenous people

Representatives must first comply with the Corporations Act 2001 HSE&C(Corporations Act) and Australian Securities Exchange Environment(ASX) Listing Rules (Listing Rules).Financial reporting  Words and terms defined in the Corporations Act and Listing Rules have the same application in this policy.

The Company has adopted a Risk Management Policy, consistent with Australia/New Zealand Standard 4360, which clearly defines responsibilities for managing risk under the Company’s risk management process. Material risks of the Company’s business, including operational, financial, legal and compliance risks related to business transactions, are required to be regularly identified, managed, monitored and reported. Methods for treating and mitigating risks include transferring, reducing, accepting or passing on risks following assessment using a variety of methods.

 

Primary responsibility for managing risk rests with the Company’s management, while the Board, through its Audit & Risk Committee, retains ultimate responsibility for risk management.

The Insider Trading Prohibition

One of the cornerstones of the Company’s risk management approach is a well defined system of delegated authorities with respect to the commitment of capital and an investment approval process which brings rigour to the selection, assessment and approval of investment risks. Matters such as legal, accounting, tax and general risk assessment issues are considered in each case. The Company’s most senior Executives and the Board are involved in major decisions.

The Corporations Act states that it is an offence for a person who possesses information that is not generally available and knows or ought reasonably to know that it is not generally available and that, if it were, a reasonable person would expect it would have a material impact on the price or value of a security, including an option, issued by the Company, to:

Material risks are reported to the Board through the Audit & Risk Committee and the Board has worked with management to implement policies and processes to address particular identified risks. The Board participates in regular updates (as required) from management on material aspects of the business of the Company, including material risks. In the case of any particular major risk materialising, relevant members of senior management and the Managing Director/CEO/General Manager are responsible for ensuring the Board is fully informed of, and for discussing with the Board, the steps taken to address that risk.
1. trade in (i.e. apply for, acquire or dispose of, or enter into an agreement to do any of these things) securities issued by the Company;
2. procure another person (e.g. a family member, friend, or family company, superannuation fund or trust) to trade in securities issued by the Company; or
3. directly or indirectly communicate, or cause to be communicated, the information to another person if the person knows or ought reasonably to know that the person to whom the information is made known may use the information to trade in or procure another person to trade in securities issued by the Company.

 

It is the responsibility of each Representative to ensure that they do not breach the insider trading prohibition. Breaches of the insider trading prohibition are considered serious and may result in disciplinary action being taken by the Company which may include dismissal from employment. Additionally, there may be significant criminal and civil liability and penalties (including imprisonment) imposed on those who breach the law concerning insider trading.

 

Dealing in securities of other companies

The insider trading rules also apply to dealings with securities in other companies. Representatives must not deal in securities of other companies if they possess “inside information” in relation to the relevant company by virtue of their position in the Company. Representatives are also bound by confidentiality in relation to the inside information obtained about third parties in the course of performing their duties in the Company.

 

Obtaining clearance to trade outside of Precluded Periods

Representatives may only deal in Company securities outside of Precluded Periods as follows:

Chairman : The Chairman must not deal in Company securities without first submitting a written notification ( Board CharterNotification ) to the Chair of the Audit Committee and the Company Secretary before commencing the transaction and must trade within seven days of submitting the Notification. The Chairman must subsequently notify the Company Secretary in writing of any trade that has occurred.

Directors Code of Conduct: Directors (other than the Chairman) must not deal in Company securities without first submitting a Notification to the Chairman and the Company Secretary before commencing the transaction and must trade within seven days of submitting the Notification. The director must subsequently notify the Company Secretary in writing of any trade that has occurred.

Other Representatives: Representatives other than the Chairman and directors must not deal in Company securities without first submitting a Notification to the Company Secretary before commencing the transaction and must trade within seven days of the Notification. Share Trading Policy

 

Precluded Periods Audit & Risk Committee




Our Business
• where a Representative is a trustee, trading in securities of the Company by that trust provided the Representative is not a beneficiary of the trust and any decision to trade during a Precluded Period is taken by other trustees or by the investment managers independently of the Representative;
• undertakings to accept, or the acceptance of, a takeover offer;Overview
• trading under an offer or invitation made to all or most of the security holders, such as, a rights issue, a security purchase plan, a dividend or distribution reinvestment plan or an equal access buy-back, where the plan that determines the timing and structure of the offer has been approved by the Board. This includes decisions relating to whether or not to take up the entitlements and the sale of rights to entitlements under a renounceable pro rata issue; andGas Industry