Securities Trading Policy

Dealings by Directors and Key Management Personnel in Securities of Sumatra Copper & Gold plc

1. Overview

This statement sets out the policy of Sumatra Copper & Gold plc (‘Sumatra’) for directors and key management personnel dealing in Securities of Sumatra. It summarises the law relating to insider trading and sets trading windows when directors and key management personnel may be entitled to trade.
For the purposes of this policy “Securities” means shares and other instruments considered to be a security for the purposes of the Corporations Act. The definition of a Security is complex and includes not only ordinary shares but also derivative instruments such as exchange traded options and warrants.

If you are in any doubt as to whether or not any instrument you wish to trade is a Security, or how this policy may affect you, should seek assistance from the Company Secretary before trading.