Securities Trading Policy

2. Insider Trading

If you have price sensitive information relating to Sumatra (including any company within the Sumatra Group) which has not been published or which is not otherwise generally available, it is illegal for you to:

(a) buy, sell or otherwise deal in Sumatra Securities;

(b) advise, procure or encourage another person (including, but without limitation, a relative, friend, family company or trust) to deal in Sumatra Securities; or

(c) pass on information to any other person if you know or reasonably know that the person may use the information to deal (or procure another person to deal) in Sumatra Securities.

It is the responsibility of each director and key management personnel (not the Company) to ensure that they do not do any of the things prohibited by insider trading laws. The consequences for breach of this law can include both civil and criminal penalties.enalties.