TRADING IN COMPANY SECURITIES
(Corporate Governance Recommendation 3.2)
POLICY and PROCEDURE


The board,
a) Notes that the law prohibits insider trading, and the Corporations Act and the ASX Listing Rules require disclosure of any trading undertaken by directors or their related entities in the company’s securities and,
b) Wishes to identify the circumstances under which it would be appropriate for designated officers can buy or sell securities in the company,


POLICY

The following policy is adopted and Procedures established in respect of a designated officer, either directly or indirectly (including others acting on their behalf), dealing in the Company’s securities.

The overriding policy is that there be no dealings in the Company’s securities, whether in permitted periods or at any other time:

When a designated officer is in possession of inside information, or
Where the dealing is for short-term or speculative gain, or
Within a period that is 72 hours prior to and 48 hours after any announcement.
Apart from these restrictions, a designated officer who has access to inside information should, unless there are special circumstances, only deal in the Company’s securities in the following periods:

Within the period commencing 48 hours after the announcement of the half year and full year financial results respectively and ending 1 month after each of those announcements.
Within the period commencing 48 hours after the dispatch of the annual report made to shareholders through to one month after the annual general meeting.
A designated officer should not:

Communicate inside information or cause that information to be communicated to another person, and
Deal in the securities of outside companies about which they may gain inside information by virtues of their positions at Anadis.
“designated officer” includes directors, employees and long term consultants/contractors who are likely to be in the possession of inside information and their associates.
“inside information” is information concerning any Company’s financial position, strategy or operations, which, if made public, would be likely to have a material impact on the price of that Company’s securities.
“securities” include shares, options, financial products issued or created over the Company’s securities by a third part and associated products which operate to limit the economic risk of their security holding in the Company.

This Policy and the following Procedure are effective immediately.

PROCEDURE

The chief executive officer will ensure that this Policy is brought to the attention of all designated officers.
If any dealings are proposed, there should be prior consultation with the chairman in the case of directors, one of the non-executive directors in the case of the chairman or the chief executive officer in the case of employees and contractors.
Written confirmation of any dealings is to be given to the person who approved the dealing. Such confirmation should;
Include the date, description of the security, quantity and price,
Be noted by the recipient, and
Given to the company secretary for filing.
Directors, pursuant to their agreement with the Company, must provide sufficient information within 3 working days to allow the company to lodge Appendix 3Y with ASX
Designated officers should be aware of the need to enforce confidentiality against external advisors and contractors.
The Audit and Risk Management Committee will periodically review compliance with this Policy and report any departures.
This Policy is to be put on the Company’s website and included in the annual report along with all other Corporate Governance policies no later than 30 June, 2004.
Issued by the board of Anadis Limited 9 March ,2004