Securities Trading Policy

6. Dealing in Shares of Other Companies

If you have “price sensitive information” relating to a company other than Sumatra which is not “generally available” the same insider trading rules outlined above apply to buying and selling Securities in that company. In the course of performing your duties as an employee of Sumatra, you may obtain price sensitive information relating to another company in a variety of circumstances. Examples include, but are not limited to the following:

(a) Another company may provide price sensitive information about itself to Sumatra in the course of a proposed transaction;

(b) Another company with whom Sumatra is dealing may provide price sensitive information about a third company; or

(c) Information concerning Sumatra or actions which may be taken by Sumatra (ie a planned transaction or strategic change) could reasonably have an effect on a third party company.

Apart from the application of the insider trading rules to Securities in other companies, employees are also bound by a duty of confidentiality in relation to information obtained in the course of their duties in respect of third parties.