Swift : Revised Share Trading Policy

ASX ANNOUNCEMENT

1 July 2022

ASX:SW1

For personal use only

Revised Share Trading Policy

Company Announcements Platform

ASX Limited

20 Bridge Street

Sydney NSW 2000

Dear Sir / Madam

Please find attached a copy of the revised Share Trading Policy for Swift Networks Group Limited (Swift or the Company). A copy of the Share Trading Policy is available on the corporate governance section of the Swift Networks Group Limited website at www.swiftnetworks.com.au.

The Company notes the Share Trading Policy was not lodged with ASX within the 5 Business Days required under Listing Rule 12.10. This was an administrative oversight, and the Company has therefore taken immediate steps to address this oversight upon realisation that the Share Trading Policy was not lodged within the prescribed period.

This release has been authorised by the Company Secretary.

Yours faithfully

Suzie Foreman

Company Secretary

ASX ANNOUNCEMENT

1 July 2022

ASX:SW1

For personal use only

ABOUT SWIFT

Swift is a specialist technology company delivering network infrastructure and premium

entertainment and communications across Mining and Resources, Residential Aged Care, Retirement

Living, Government and other sectors.

We connect and engage communities through entertainment and communications solutions.

This announcement was approved and authorised for release by the Swift Board. 

FOR MORE INFORMATION, PLEASE CONTACT: 

Brian Mangano 

CEO & Managing Director

[phone] |[e-mail]

Share Trading Policy

ASX:SW1

For personal use only

Swift Networks Group Limited ("Company")

SHARE TRADING POLICY

Introduction

This document sets out the Company's policy on the sale and purchase of its securities by its Directors, employees and contractors.

The purpose of this policy is to:

• impose "Black-out" periods at various times during the year, particularly in periods leading up to an announcement of results, during which trading of the Company's securities by Directors, employees and contractors is prohibited; and
• set out procedures to reduce the risk of insider trading.

A basic explanation on insider trading is provided together with the steps taken by the Company to prevent the practice, including:

• a description of what conduct may constitute insider trading.
• the windows when Directors, employees and contractors are permitted to buy or sell securities in order to minimise the risk of insider trading.
• the steps to take when buying or selling securities in the Company.

Definition of Insider Trading

Prohibition

Insider trading is a criminal offence. A person will be guilty of insider trading if:

1. That person possesses information in relation to a company which is not generally available to the market, and if it were generally available to the market, would be likely to affect the price or value of that company's securities (i.e. information that is "price sensitive") and

For personal use only

Share Trading Policy

ASX:SW1

1. That person:
2. 1. buys or sells securities in the Company;
   2. procures someone else to buy or sell securities in the company; or
   3. passes on that information to a third party where that person knows, or ought reasonably to know, that the third party would be likely to deal in the securities or procure someone else to deal in the securities of the company.

Examples

Price sensitive information means information relating to the Company that would, if the information were publicly known, be likely to:

• Have a material effect on the price or value of its shares
• Influence persons who invest in securities in deciding whether or not to buy or sell the company's shares

The following are examples of price sensitive information which, if made available to the market, would be likely to affect the price of the Company's securities:

• The Company is considering the acquisition of another company,
• Product testing results confirming (or falling short of) the market's expectations.

Dealing Through Third Parties

A person does not need to be a Director, employee of Company to be guilty of insider trading in relation to securities in the Company. The prohibition extends to dealings by anyone, including Directors' and employees' nominees, agents or other associates, such as family members, family trusts and family companies, as well as customers and suppliers.

Contractors and External Advisors

Contractors employed by the Company shall be informed of this policy when they are appointed and are required to adhere to the policy so long as they are contracted by the Company. Breach of the policy may lead to termination of contract arrangements.

The Company's staffs dealing with external advisers needs to ensure that the advisers are aware of the insider trading rules and where these dealings cover material matters, that the issue of insider trading is covered in confidentiality documents.

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Share Trading Policy

ASX:SW1

Meaning of Securities

The rules covers shares in the Company, derivatives related to the Company's shares, whether issued by the company or not and to any traded company options. It also applies to the exercise of options, including employee options.

Related Companies

Directors, employees and contractors , where they possess inside information, should also not deal in securities of other companies with which the Company might have an association or be about to enter such association such as joint venture or farm in partners.

Guidelines for Trading in the Company's Securities

Approval Process

Directors, employees and contractors can deal in securities of the Company in the following circumstances:

1. they have satisfied themselves that they are not in possession of any price sensitive information that is not generally available to the public;
2. they have contacted the Chairman or in his absence, the Managing Director and notified them of their intention to do so and the Chairman or Managing Director indicates that there is no impediment to them doing so.

Where the Chairman wishes to deal in securities, he must contact the Managing Director, or in his absence, the Company Secretary and notify them of his intention to do so and the Managing Director or Company Secretary will indicate if there is no impediment to him doing so.

The Chairman will generally not allow directors, employees and contractors to deal in securities of the Company as a matter of course in the following periods:

1. within the period of 14 days prior to the release of annual, half yearly or quarterly results;
2. within the period of 14 days prior to the Annual General Meeting; and
3. if there is in existence price sensitive information that has not been disclosed because of an ASX Listing Rule exception.