Corporate Communications, Disclosure and Insider Trading Policy

Training Module 11 – Version 1.1For Internal Use Only

Communication Policy ®

Corporate Communications, Disclosure

and Insider Trading Policy



Preamble Public DisclosureInsider TradingConfidentiality






Ensure consistent standards and procedures for corporate communications

Ensure timely compliance with regulationsEnsure directors, officers and employees of

SIRTEX understand corporate obligations

Purpose of Policy

The objectives of this policy are:



Directors Officers Employees All other individuals authorised to speak on

“behalf of SIRTEX” (contractors, agents, distributors, proctors, consultants etc)

Application of Policy

The communication policy applies to:



Internal disciplinary actionCivil penaltiesCriminal penaltiesTermination of employment without notice

Non-Compliance

Failure to comply with this policy may result in:






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 .

Public Disclosure - Definition

Public Disclosure:



Chairman CEO CFO Company secretary Others designated in writing by the CEO and/or

the Company secretary (the “Authorised Company Representatives”).

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



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

Public Disclosure – What is material information

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



Material information is “non-public” if it has not been disseminated in a manner making it available to investors generally.

Public Disclosure – What is non-public information



We must organise and facilitate dissemination of non-material informationSpeaking engagements and presentations by employees of SIRTEX must be approved in advanceDirectors, 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.

Public Disclosure of non-material information



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.

Public Disclosure - Reporting of Violations






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.

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.

Insider Trading Policies



There are three scheduled permitted trading periods each year. These follow bi-annual disclosures of earnings, and AGM.

Insider Trading Policies - Blackout Periods

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

The trading periods are as follows:






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.

Confidentiality



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.

Confidentiality

The following procedures should be observed at all times:



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.

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.

Confidentiality


