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Communication Policy
®
Training Module 11 – Version 1.1
Corporate Communications,
Disclosure
and
Insider Trading Policy

Communication Policy
®
Training Module 11 – Version 1.1
Preamble
Public Disclosure
Insider Trading
Confidentiality

Communication Policy
®
Training Module 11 – Version 1.1
Preamble
Public Disclosure
Insider Trading
Confidentiality

Communication Policy
®
Training Module 11 – Version 1.1
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

Communication Policy
®
Training Module 11 – Version 1.1
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)

Communication Policy
®
Training Module 11 – Version 1.1
Non-Compliance
Failure to comply with this policy may result in:
 Internal disciplinary action
 Civil penalties
 Criminal penalties
 Termination of employment without notice

Communication Policy
®
Training Module 11 – Version 1.1
Preamble
Public Disclosure
Insider Trading
Confidentiality

Communication Policy
®
Training Module 11 – Version 1.1
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 .

Communication Policy
®
Training Module 11 – Version 1.1
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”).

Communication Policy
®
Training Module 11 – Version 1.1
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:


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
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
Financials
Change in corporate objectives
Product discovery
FDA activities
Legal action
Change in management

Communication Policy
®
Training Module 11 – Version 1.1
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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Communication Policy
®
Training Module 11 – Version 1.1
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.

Communication Policy
®
Training Module 11 – Version 1.1
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.

Communication Policy
®
Training Module 11 – Version 1.1
Preamble
Public Disclosure
Insider Trading
Confidentiality

Communication Policy
®
Training Module 11 – Version 1.1
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.

Communication Policy
®
Training Module 11 – Version 1.1
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.

Communication Policy
®
Training Module 11 – Version 1.1
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

Communication Policy
®
Training Module 11 – Version 1.1
Preamble
Public Disclosure
Insider Trading
Confidentiality

Communication Policy
®
Training Module 11 – Version 1.1
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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Communication Policy
®
Training Module 11 – Version 1.1
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.
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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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Communication Policy
®
Training Module 11 – Version 1.1
Confidentiality
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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.
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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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Communication Policy
®
Training Module 11 – Version 1.1
Confidentiality
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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.
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Extra copies of confidential documents should be shredded
or otherwise destroyed.
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Access to confidential electronic data should be restricted
through the use of passwords.

Communication Policy
®
Training Module 11 – Version 1.1
Preamble
Public Disclosure
Insider Trading
Confidentiality
