PowerPoint-Pr

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Corporate Communications, Disclosure and
Insider Trading Policy
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• Preamble
• Public Disclosure
• Insider Trading
• Confidentiality

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• Preamble
• Public Disclosure
• Insider Trading
• Confidentiality

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Purpose of Policy
The objectives of this policy are

• Ensure consistent standards and procedures for
  corporate communications
• Ensure timely compliance with regulations
• Ensure directors, officers and employees of
  SIRTEX understand corporate obligations

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Application of Policy
The communication policy applies to

• Directors
• Officers
• Employees
• All other individuals authorised to speak on
  behalf of SIRTEX (contractors, agents,
  distributors, proctors, consultants etc)

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Non-Compliance
Failure to comply with this policy may result in

• Internal disciplinary action
• Civil penalties
• Criminal penalties
• Termination of employment without notice

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• Preamble
• Public Disclosure
• Insider Trading
• Confidentiality

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Public Disclosure - Definition
Public Disclosure
It is against the law and this policy for any
person acting on behalf of SIRTEX to selectively
disclose material and non-public information to
securities professionals or to stockholders of
SIRTEX under circumstances where it is reasonably
foreseeable that the stockholder may be likely to
trade on the basis of such information, unless
the information is simultaneously disclosed to
the public .
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Public Disclosure Who is acting on behalf of
SIRTEX
The only individuals authorised to represent
SIRTEX in its dealings with securities
professionals and stockholders, including
institutional investors, are

• Chairman
• CEO
• CFO
• Company secretary
• Others designated in writing by the CEO and/or
  the Company secretary (the Authorised Company
  Representatives).

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Public Disclosure What is material information
Material information is any information that a
reasonable investor would consider important in
making an investment decision. This includes but
is not limited to

• Financials
• Change in corporate objectives
• Product discovery
• FDA activities
• Legal action
• Change in management

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Public Disclosure What is non-public information
Material information is non-public if it has
not been disseminated in a manner making it
available to investors generally.
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Public Disclosure of non-material information
We must organise and facilitate dissemination of
non-material information Speaking engagements and
presentations by employees of SIRTEX must be
approved in advance Directors, officers or
employees who are not authorised company
representatives must not respond to inquiries
from the investment community, the media or
others, unless specifically asked to do so by an
authorised company representatives.
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Public Disclosure - Reporting of Violations
If a director, officer or employee of SIRTEX
becomes aware that non-public material
information has been selectively disclosed by a
person acting on behalf of SIRTEX, the Chairman,
CEO, CFO, director, company secretary should be
contacted immediately.
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• Preamble
• Public Disclosure
• Insider Trading
• Confidentiality

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Insider Trading Policies
All employees, officers and directors of SIRTEX
who have knowledge of undisclosed material
information relating to SIRTEX or its business
are expressly prohibited from buying or selling,
exercising options to buy or sell or tipping
someone else to buy or sell (or not to buy or
sell), securities of SIRTEX unless and until such
information has been publicly disclosed and
disseminated.
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Insider Trading Policies
This prohibition applies to family members and
others living in your household who gain access
to or become aware of inside information. All
employees, officers directors of SIRTEX are
also responsible for compliance within their own
environment.
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Insider Trading Policies - Blackout Periods
There are three scheduled permitted trading
periods each year. These follow bi-annual
disclosures of earnings, and AGM.
The trading periods are as follows

• The trading window is defined as the period two
  days after and no later than 45 days after the
  company has released its annual or half yearly
  results to the market, or held its AGM.
• Anytime outside these trading windows is to be
  considered a black-out period

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• Preamble
• Public Disclosure
• Insider Trading
• Confidentiality

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Confidentiality
All directors, officers and employees of SIRTEX
who know material information relating to SIRTEX
that has not been communicated to the public are
prohibited from communicating that information
internally or externally to anyone else, except
as may be necessary in the course of business to
persons who need-to-know the information in
order to perform his or her responsibilities at
SIRTEX.
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Confidentiality
The following procedures should be observed at
all times

• Documents and files containing confidential
  information should be kept in a safe place to
  which access is restricted to individuals on a
  need-to-know basis.
• Confidential matters should not be discussed in
  places where the discussion may be overheard,
  such as elevators, hallways, restaurants,
  airplanes or taxis.
• Use of analogue wireless telephones or other
  analogue wireless devices to discuss confidential
  matters should be avoided, where possible.

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Confidentiality

• Confidential documents should not be read or
  displayed in public places and should not be
  discarded where others can retrieve them.
• Employees must ensure that they maintain the
  confidentiality of information in their
  possession outside of the office as well as
  inside of the office.
• Transmission of documents by electronic means,
  such as by fax or directly from one computer to
  another, should be made only where it is
  reasonable to believe that the transmission can
  be made and received under secure conditions.

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Confidentiality

• Unnecessary copying of confidential documents
  should be avoided and documents containing
  confidential information should be promptly
  removed from conference rooms and work areas
  after meetings have concluded.
• Extra copies of confidential documents should be
  shredded or otherwise destroyed.
• Access to confidential electronic data should be
  restricted through the use of passwords.

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• Preamble
• Public Disclosure
• Insider Trading
• Confidentiality

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