COALWORKS LIMITED 
By COALWORKS Limited ABN 51 114 702 831
Level 5, 44 Miller Street, North Sydney NSW 2060 Australia
Ph: +61 2 9922 1344 Fax: +61 2 9922 4288
Email: info@coalworks.com.au
www.coalworks.com.au
Securities Trading Policy1 Introduction and Purpose1.1 These guidelines set out the policy on the sale and purchase of Securities in Coalworks Limited (ACN 114 702 831) (“Coalworks or “Company”) by its Designated Officers. The Company includes a subsidiary of the Company.
1.2 The Company has determined that its Designated Officers are its Key Management Personnel, including Directors and the direct reports of the Company’s Managing Director, and any other person designated by the company secretary as a Designated Officer for the purposes of this policy.
1.3 Designated Officers, employees and consultants of the Company are encouraged to be long- term holders of the Company’s Securities. However, it is important that care is taken in the timing of any purchase or sale of such Securities.
1.4 Key Management Personnel are those persons having authority and responsibility for planning, directing and controlling the activities of the entity, directly or indirectly, including any Director (whether executive or otherwise) of the Company.
1.5 Securities includes ordinary shares of the Company and any structured financial product, swap, futures contract, option, warrant, or other derivative over any ordinary share of the Company, whether issued by the Company or a third party, and any other interest in an ordinary shares of the Company; including units in trusts, debentures, prescribed interests and rights or options to subscribe for shares, units, debentures or prescribed interests.
1.6 Trade or Trading includes:
a) applying for, acquiring or disposing of, Securities;
b) entering into an agreement to apply for, acquire or dispose of, Securities; and
c) granting, accepting, acquiring, disposing, exercising or discharging an option or other right or obligation to acquire or dispose of Securities.
2.1 This policy imposes trading restrictions on Designated Officers (as defined) and any body corporate, nominee company, superannuation fund, superannuation trust and family trust to which the Designated Officer controls or any investment manager on their behalf.
3 Insider Trading Laws3.1 Insider trading laws cover all directors and employees (including contractors) of the Company. If you have any inside information which is not publicly known, it may be a criminal offence for you to:
a) trade in Coalworks Securities,
b) advise or procure another person to trade in Coalworks Securities, or
c) pass on inside information to someone else – including colleagues, family or friends – knowing (or where you should have reasonably known) that the other person will use that information to trade in, or procure someone else to trade in, Coalworks Securities.
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Securities Trading Policy3.2 This offence, called "insider trading", can subject you to criminal liability including large fines and/or imprisonment, and civil liability, which may include being sued by another party or Coalworks, for any loss suffered as a result of illegal trading or being fined under civil penalty provisions.
3.3 What is “Inside Information”?
