6. Trading Excluded from the Policy
6.1 The following types of trades are expressly excluded from the operation of this policy:
a) investing or trading in a fund or scheme where the investment decisions are made by a third party, provided that the fund or scheme does not invest exclusively in MVP’s shares;
b) trading in securities by a restricted person as a trustee – who is not also a beneficiary of the trust – and the decision to trade is made by other trustees or investment managers independently of the restricted person;
c) acceptance of a takeover offer;
d) trading under an offer or invitation made to all or most security holders, including DRPs, share purchase plans and rights issues and an equal access buy-back, where the timing and structure of the plan has been approved by the board;
7. Notification
7.1 Once a trade of shares has been made by or for an Employee, its completion, including volume must be reported in writing to the Company Secretary.
7.2 Directors of the Company must report all acquisitions or disposals of shares without exception, including date, price, volume, whether the acquisition or disposal occurred during a Closed period where prior written clearance was required and, if so, whether prior written clearance was provided, so that the Company can comply with the ASX reporting obligations.
8. Breach of Insider Trading Prohibitions
8.1 Any breach of this policy must be immediately advised to the Company Secretary, who in turn will report to the Board.
8.2 A breach of this policy may result in:
a) criminal liability – penalties include heavy fines and imprisonment;
b) civil liability – legal action by another party or MVP for any loss suffered as a result of illegal trading activities; and
c) disciplinary action including dismissal.
9. Definitions
“ASX” means Australian Stock Exchange
“Board” means the board of directors of Medical Developments International Limited
“Chairman” means Chairman of the Board of Directors
“Closed Period/Black Out Period” has the meaning given to that term in clause 4.3(a) & 4.3(b)
“Dealing” includes:
a) Any application for acquisition or disposal of any shares;
b) Entering into agreement to apply for, acquire or dispose of any shares; and’
c) The grant, acceptance, acquisition, disposal, exercise or discharge of any option or other right or obligation to acquire or dispose of shares
“MVP” means ASX code for Medical Developments International Limited