Securities Trading Policy

7. Limitation Periods for Buying and Selling Securities - Trading Windows

Whilst it is unlawful to trade at any time if a director or key management personnel has inside information, there are other periods when trading by directors and key management personnel who generally have access to non-public information is unwise due to the perception that they may possess price sensitive information that is not generally available. For this reason, Sumatra has limited the times when directors and key management personnel may buy or sell Securities. These periods are limited to a period of 60 days after the release of the half year results, full year results and the holding of the annual general meeting. Other periods are closed periods in which directors and key management personnel are prohibited from trading in the Company's securities.

It is recognised that a person in severe financial hardship or other exceptional circumstances may need to dispose of Securities outside the specified windows. In such cases any director or key management personnel is required to seek the prior written approval of the Chairman who may approve the transaction with respect to the exceptional circumstances. Alternatively, the exception relating to the Executive Share Option Plan set out in section 9 of this policy may apply. Any approval or exception is subject to the overriding obligation of the director or key management personnel to comply with insider trading laws and the obligations under listing rules 12.9, 12.10 and 12.12.