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 About Us |
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- Why Invest in Moby
- Exploration and Investment Philosophy
- Capital Structure
- Directors, Company Secretary and Management
- Moby holds a portfolio of offshore petroleum exploration permits with the potential for high impact in the event of exploration success – see Projects;
- Forward committed exploration expenditure is limited which means a low ‘cash burn’ rate;
- Fully carried by Apache through a 3D seismic programme in the WA-359-P and WA-409-P permits and a well in one of those permits, should Apache elect to drill a well;
- Remaining exploration permits have potential for further farmouts;
- Success in any one or more of these permits will have transformational share price impact;
- Cornea-3 drilled in December 2009 ‘firmed up’ information on hydrocarbon contacts and reservoir qualities of the Cornea accumulation;
- Moby is committed to investing in transformational resource based opportunities – see Exploration and Investment Philosophy below;
- Highly experienced management team with depth of experience in oil and gas exploration companies and a track record of successful deal making – see Directors, Company Secretary and Management below;
- A commitment to sound corporate governance practices – see Corporate Governance below.
EXPLORATION AND INVESTMENT PHILOSOPHY
- Be an entry point for investment in high quality international scale opportunities;
- Explore in permits with low obligations in geologically prospective areas and clear pathways to commercialisation (e.g. Judith gas discovery in Gippsland Basin);
- Acquire known resources with development potential (e.g. Cornea);
- Conduct initial exploration (seismic data acquisition and the like) on own account;
- Focus on risk reduction and generally avoid direct funding of high risk, expensive drilling obligations;
- Farm out to substantial industry participants with the expertise to assess high value opportunities with development potential (e.g. Apache and the scope in the WA-359-P and WA-409-P permits).
- 322,000,862 ordinary fully paid shares on issue – listed on ASX under code MOG;
- 40,662,282 options granted with exercise price of 12 cents each and expiry date of 30 June 2013 – listed on ASX under code MOGOA;
- 2,700,000 executive options granted with exercise price of 25 cents each and expiry date of 10 November 2013;
DIRECTORS, COMPANY SECRETARY AND MANAGEMENT
Mr E Geoffrey Albers LL.B, FAICD (Chairman and Chief Executive Officer)
Mr Lance E Coburn B. Comm (Hons), FCPA, GAICD (Non-Executive Director)
Mr Robert J Coppin B.Sc.(Hons) (Non-Executive Director)
Mr Graeme A Menzies LL.B (Non-Executive Director)
Mr J G (Jack) Tuohy BCA, CA (Company Secretary)
Dr Simon J Sturrock B.Sc. (Hons), PhD, FGS (Exploration Manager)
Mr Robert J Wright B Bus, CPA (Chief Financial Officer)
Mr E Geoffrey Albers LL.B, FAICD (Chairman and Chief Executive Officer)
Mr Albers has over 35 years experience as a director and administrator in corporate law, petroleum
exploration and resource sector investment. He is a law graduate of the University of Melbourne
and, after being admitted in 1969 as a Solicitor of the Supreme Court of Victoria, held a corporate
practicing certificate in Victoria until 2001.
Mr Albers first became involved in oil exploration in 1977 when companies associated with him applied for and were awarded exploration permits in the offshore Gippsland and Bass Basins. Exploration in one of these permits, T/14P, led directly to the discovery of the Yolla Gas/Condensate Field in Bass Strait, which is now being produced by Origin Energy Limited and others.
In the early 1980's Mr Albers formed Cue Energy Resources Limited and Southern Petroleum N.L. in New Zealand. Cue is ASX-listed and has a significant interest in the Maari oilfield development in New Zealand, the unitised SE Gobe oilfield in PNG and the Oyong oil and gas development in offshore Indonesia. Mr Albers was a director of Cue until August 2009. Southern Petroleum became a successful production company through its interest in the Waihapa oilfield and is now a subsidiary of Shell New Zealand.
Mr Albers founded ASX-listed Octanex N.L. and he is a director and a substantial shareholder in that company. Octanex has substantial offshore exploration interests in Australia and New Zealand. He was also a founder of ASX-listed MEO Australia Limited and is a former director of that company.
MEO is pursuing the development of a $2 billion gas processing plant on Tassie Shoal in the Timor Sea, 300 kms north-west of Darwin. He then founded Bass Strait Oil Company Ltd, an ASX-listed company which has developed a portfolio of interests in the offshore Gippsland Basin and is a niche explorer in that basin. Mr Albers was a director of Bass from its formation until August 2009.
Mr Albers was instrumental in the formation of Moby in 2003 and in its listing on ASX in 2004. He
is a substantial shareholder in the Company. In addition, Mr Albers is a director of Exoil Pty Ltd, a
company listed on NSX until June 2011, and has interests in a number of unlisted public and private
companies active in exploration for oil and gas in Australian offshore waters. He is a member of the
Petroleum Exploration Society of Australia and has been a Director of Moby since its incorporation on
13 October 2003.
Mr Lance E Coburn B.Comm (Hons), FCPA, GAICD (Non-Executive Director)
Mr Coburn was employed by BHP Group for 37 years until July 2000. Some of the later positions
he held in BHP were: President, BHP Steel USA, Vice President Minerals Services, Group General
Manager Minerals Finance, Group General Manager Steel International, Managing Director BHP New
Zealand Steel and BHP Group General Manager Petroleum Finance. Earlier in his career with BHP
he held treasury and finance positions and during this time he was a director of the Whyalla Credit
Union. From 1987 to 1989 he was a director of then US listed company, Hamilton Oil & Gas Inc.
Since leaving BHP, Mr Coburn has worked and consulted in a part-time capacity as well as holding
roles in the not-for-profit sector. These including being a director and past chairman of the Advisory
Board of the Parent-Infant Research Institute at the Austin Hospital and a member of the Audit
Committee of the Anglican Diocese of Melbourne. Mr Coburn is a director of Big Sky Credit Union Ltd
and he has been a Director of Moby since 17 March 2004.
Mr Robert J Coppin B.Sc. (Hons) (Non-Executive Director)
Mr Coppin graduated from the University of Adelaide in 1965 with a Bachelor of Science with
Honours, majoring in Geology and Physics. For the next 45 years he worked in the petroleum
exploration industry, beginning with the South Australian Department of Mines, then moving to Esso
in Australia and Malaysia where, as Exploration Projects Manager, he was involved in several oil and
gas discoveries in the Malay Basin.
After a period with Exxon USA in Houston, Mr Coppin returned to Esso Australia as Western Division Manager in charge of exploration in Western Australia and the Delhi interests in the South Australian Cooper Basin. He then joined Santos Limited as South East Asia Exploration Manager and in this position was responsible for Santos’ exploration interests in Papua New Guinea and Malaysia and new venture activities in Vietnam, Cambodia, Thailand and Myanmar.
From 1994 to 2010, Mr Coppin was with Cue Energy Resources Limited where he oversaw that company’s focus on Papua New Guinea, Indonesia, New Zealand and Australia. For the last 12 of those years he was Chief Executive Officer of Cue.
Mr Coppin is a former member of the Australia Petroleum Production and Exploration Association where he was a councillor for 10 years and for 8 years was chairman of the APPEA exploration committee. He has been a Director of Moby since 1 March 2011.
Mr Graeme A Menzies LL.B (Non-Executive Director)
Mr Menzies is a barrister and solicitor. He graduated from Melbourne University in 1971 and qualified
for admission to the degree of Master of Laws in 1975. He was admitted to practice in 1972.
Since 1987 he has carried on practice as a sole practitioner under the name of Menzies & Partners. In the course of his legal practice Mr Menzies has been involved in a wide range of activities including
takeovers, litigation in respect thereof, numerous capital raisings and corporate reconstructions. He has been involved as a lawyer in the listing of a large number of public companies ranging from junior explorers to substantial mining companies. Over recent years his activities have focused primarily on corporate reconstructions and capital raisings.
Mr Menzies is a director of Octanex N.L. and Exoil Pty Ltd, as well of a number of private and unlisted public companies. He has been a Director of Moby since its incorporation on 13 October 2003.
Mr J G (Jack) Tuohy BCA, CA (Company Secretary)
For all but two years since 1986, Mr Tuohy has acted as Company Secretary to public listed
companies in New Zealand. The first half of that period he spent in the oil and gas sector, initially
administering three oil and gas exploration companies in which Messrs Albers and Willis were
directors and which they had originally taken to listing. He then acted for only one of them, Southern
Petroleum N.L., when it became a successful production company. Following the privatisation of
Southern Petroleum, Mr Tuohy acted in a forensic accounting capacity in a multi party legal action,
then returning to a public company secretarial position in the motor vehicle industry where he spent
10 years.
In these positions Mr Tuohy has been involved in the various aspects of public and private company administration, especially as this relates to the oil and gas exploration sector and to public listed company activities, obligations and requirements. In 2008 he relocated to Australia and acts as Company Secretary for a number of listed and unlisted public companies: including Octanex N.L. and Exoil Pty Ltd and is a director of Bass Strait Oil Company Limited. Mr Tuohy is a chartered accountant in New Zealand.
Dr Simon J Sturrock B.Sc. (Hons), PhD. FGS (Consultant Geoscientist/Exploration Manager)
Octanex’s leading technical consultant is Strat Trap Pty Ltd; a successful geological interpretation
consultancy based in Perth and whose principal technician and director is Dr Simon Sturrock.
Dr Sturrock is a seismic interpreter and sequence stratigrapher with 27 years international and Australasian exploration and development experience, including 11 years with British Petroleum and seven years as Exploration Manager of Moby. He possesses a unique and powerful skills combination for stratigraphic prediction and has a proven track record in accurately predicting reservoir and seal distribution that has substantially reduced costs and assisted in the discovery of significant hydrocarbons. Dr Sturrock has an extensive knowledge of practical sequence stratigraphy and he is highly experienced in applying these skills to field appraisal and development, exploration prospect and play fairway evaluation and risk analysis.
Dr Sturrock is a member of the Petroleum Exploration Society of Australia, the American Association of Petroleum Geologists, the Petroleum Exploration Society of Great Britain, the Australian Society of Exploration Geophysicists and the Formation Evaluation Society of Australia, as well as being a Fellow of the Geological Society of London. He has also carried out post-doctoral research at the British Museum that was funded by British Petroleum.
Mr Robert J Wright B Bus, CPA (Chief Financial Officer)
Mr Robert Wright is a senior financial professional with over 20 years commercial experience in the
resource, energy and manufacturing industries gained at various companies and locations, including
14 years at BHP. He is Chief Financial Officer for several listed exploration companies and is a
member of CPA Australia.
The Directors are responsible for the strategic direction of the Company, the identification and implementation of corporate policies and goals and monitoring of the business and affairs of the Company on behalf of the Shareholders.
This section includes information on how the Company and the Board address, on an ongoing basis, the specific requirements of ASX in relation to corporate governance in general. More specifically, it addresses the operation of the Board itself, Board committees and their charters, the Company’s code of ethics and its share trading policy for designated individuals (as those individuals are defined).
Important to a culture of actively addressing the area of corporate governance is the Board’s ongoing review of the Company’s relevant and existing policies and practice. To this end, the Board annually reviews the Company’s corporate governance activities by benchmarking against the latest Corporate Governance Principles and Recommendations (“principles & recommendations”) issued by the ASX Corporate Governance Council (“Council”). The Board has adopted the elements of the eight principles & recommendations that are appropriate to the Company. Details of the governance practices applied by the Company and specific instances where the Company has followed alternatives to the Council’s eight principles & recommendations are set out below.
Given the size of the Company to date, with limited activities, limited resources, having a Board of four Directors and no employees, it is not able to introduce diversity policies or practically establish a series of separate committees to address specific areas of corporate governance. Consequently, corporate governance is (generally) dealt with by the Board under the terms of reference of its own charter. It also acts as committees in relation to the various areas or issues required to be considered, utilising formal terms of reference for the activities of those committees.
As noted, the capacity of the Company to comply with the principles & recommendations is limited because of the present size and structure of the Company and the Board. Currently, the Board comprises Mr EG Albers and Mr GA Menzies, executive and non-executive directors respectively who are not independent, and Mr LE Coburn and Mr RJ Coppin, non-executive directors who are independent. Mr Albers is the Board Chairman and Chief Executive Officer (“CEO”) and is not independent because he and his associates have substantial shareholdings in the Company. Mr Menzies is not independent because of past and present professional and commercial relationships with the Company.
Separate from its own charter (the main terms of which are detailed below), the Board has developed formal charters that incorporate the terms of reference under which it addresses the areas and functions of audit, compliance, remuneration and nominations - these are also explained below. The charters introduce a formal structure of objectives and functions for the Board to apply when addressing these aspects of the Company’s corporate governance, in anticipation of an expanded Board being able to address these functions via committees constituted with the recommended personnel.
The Board has established itself as two committees to separately address the areas of audit & compliance and remuneration & nominations – currently each of the Directors is a member of those committees. The Board has not established separate committees to address risk management or health, safety and environment, with such issues currently dealt with by the Board as a whole.
In relevant situations, any interested Director(s) are expected to abstain or be absent from Board or committee deliberations as required either by the Corporations Act 2001 (“Act”) or as necessary to avoid conflict or possible breach of their fiduciary duties.
The Company’s charter for its Board (“Charter”) provides that the Directors are appointed by the Shareholders and are (individually and collectively) responsible for the activities of the Company in accordance with legal and regulatory requirements and the Company’s Constitution.
The Charter sets out that the primary role of the Board is to create shareholder wealth (with a long term bias) and, in that context, to have due regard to the interests of other stakeholders. The Board is to achieve this by:
- providing leadership of the Company through setting the Company's direction, strategies and financial objectives within a framework of prudent and effective controls which enable risk to be recognised, assessed and managed;
- ensuring the Company has effective processes and systems in place to enable the Board to plan strategically, review current strategy, consider alternative strategies, monitor corporate performance and capabilities and recognise and oversee the management of risk;
- setting, overseeing and maintaining the Company's values, corporate governance framework, compliance with regulatory and ethical standards and ensuring that these are adhered to in the interests of the Company's shareholders, employees, customers, suppliers and the communities in which it operates;
- safeguarding the reputation of the Company;
- ensuring there is an effective balance between the delegation of responsibility for the day-to-day operation and management to the CEO and the role of the Board in monitoring, guiding and providing oversight;
- ensuring that the necessary financial and human resources are in place for the Company to meet its objectives;
- ensuring that the performance of Management, and the Board itself, is regularly assessed and monitored;
- promoting a culture where transparent and timely information is shared between management and the Board and where there is opportunity to advance proposals, challenge views, assumptions and beliefs in an environment of trust, respect and openness;
- ensuring effective communication with Shareholders; and
- appointing, terminating and reviewing the performance of the CEO.
The Charter also provides specific provisions and guidance to the Board in relation to:
- Composition of the Board;
- Selection of Directors;
- Board committees and their makeup;
- Board authorities and accountabilities;
- Taking independent advice;
- Individual responsibilities;
- Conduct of Board meetings and record-keeping; and
- Review of Board and Director performance.
The Board reviews the Charter at least once a year to ensure it remains consistent with the Board’s objectives and responsibilities.
The function of an Audit & Compliance Committee is to give additional assurance regarding the quality and reliability of financial information used by the Board and regarding the financial information provided by the Company pursuant to its statutory reporting requirements.
Aspects of the audit and compliance function to be addressed by this Committee, as part of its terms of reference, are:
- to consider any matters relating to the financial affairs of the Company;
- compliance with statutory requirements;
- adherence to applicable Listing Rules; and
- issues relating to internal and external audit.
Additional to those aspects, the Board examines any other matters of an audit or compliance nature that come to its attention or are referred to it.
At least annually, the non-executive Directors on this Committee may meet separately with the (external) Auditors.
Nominations & Remuneration Committee
The core remuneration function of this Committee is reviewing the remuneration policies and practices of the Company. Where relevant, this review covers compensation arrangements for executives, superannuation arrangements, the requirements for an employee share and option plan, performance reviews, succession planning and the fees of non-executive Directors.
When addressing these areas, the non-interested Directors who carry out these functions have access to independent advice and comparative studies on the appropriateness of remuneration arrangements.
In the event of exploration success or expansion of the Company’s operations beyond those currently capable of being undertaken, the remuneration levels of Directors may increase; but not beyond the approved limit for directors’ fees set from time to time by the Shareholders in general meeting. It should be noted that directors’ remuneration as fixed in general meeting does not include salary (and associated benefits, including superannuation) payable to executive Directors.
The functions of the Committee in relation to nominations are:
- to identify and recommend candidates to fill Board vacancies as and when they arise;
- before recommending an appointment, to evaluate the balance of skills, knowledge and experience on the Board and, in the light of that evaluation, to determine the role and capabilities required for the appointment;
- to make recommendations to the Board with respect to the:
(a) re-appointment of any non-executive Director at the conclusion of their specified term of office; and
(b) re-election by Shareholders of any Director under the retirement by rotation provisions in the Company’s Constitution; - to formulate succession plans for both non-executive and executive Directors, taking into account the expertise required on the Board in the future;
- to review the structure, size and composition of the Board; and
- to consider such other matters relating to Board nomination or succession issues as may be referred to it by the Board.
The Board of Directors adherence to the ASX Principles & Recommendations of Corporate Governance
Principle 1 – Lay Solid Foundations for Management and Oversight
The Board’s primary role is the stewardship of the shareholders’ funds with the objective of creating long term shareholder value. In fulfilling this role, the Board accepts overall responsibility for corporate governance. A board charter, which outlines the framework for its operation and of those functions delegated to the management, has been outlined above.
The Company’s senior executives are currently an Executive Director, the Company Secretary, the Chief Financial Officer (“CFO”) and a Consultant Geoscientist/Exploration Manager – relevant information on each individual is set out above at Directors, Company Secretary and Management. Where necessary, the Company utilises non-executive directors and contractors to provide expertise for technical, legal and administrative services.
The performance evaluation of the relevant Director is undertaken together with the other members of the Board. This evaluation comprises a board performance appraisal and director self-assessments that are reviewed by the Chairman.
Principle 2 – Structure the Board to Add Value
Board Composition
The Board currently comprises four Directors. One is an executive director (Mr Albers, Chairman and
CEO) and the other three are non-executive directors who are both independent (Messrs Coburn and
Coppin) and not independent (Mr Menzies). The qualifications, skills, expertise, financial and industry
experience and period in office of each Director are set out above at Directors, Company Secretary
and Management.
Given the size of the Board and the scope of the Company’s activities, the Company does not have a diversity policy, so is unable to comply with this Principle in terms of board composition.
The Chairman administers the procedure for Directors to seek independent professional advice, at the Company’s expense, to assist them to fulfill their duties and obligations.
Independence
At the present stage of the Company’s development, and given its current size and structure, the
resources available to the Board to carry out the Company’s activities have been limited. As such,
the Board does not have a majority of independent directors, so the Company is unable to comply
with this Principle in terms of board composition.
The Board determined that, where these are available, the specific skills of non-executive directors may be called upon from time to time to assist the Management. The Board has established a level of remuneration paid for those services as a materiality threshold to determine a director’s non- executive status.
Role of the Chairman
Mr Albers is not an independent director. The Board considers that his lack of independence and
carrying out executive duties for the Company do not hinder the effective performance of his role
as Chairman and CEO. The Company does not therefore comply with this Principle in terms of
independent chairmanship.
Given the size of the Board and the scope of the Company’s activities, the Company does not have a separate nominations committee, with the functions of such a committee undertaken by the Board under a charter that describes the terms of reference for a Remuneration and Nominations Committee.
As noted in Principle 1, ‘board performance appraisals’ and ‘director self-assessments’ are undertaken annually.
Principle 3 – Promote Ethical and Responsible Decision-making
The Board has established a:
- Board Charter, outlining the responsibilities and activities of the board and individual directors within legal and regulatory requirements and the Company’s constitution - see above;
- committee charters, describing the terms of reference for the operation of an Audit & Compliance Committee and a Remuneration & Nominations Committee - see above;
- Code of Ethics, setting out the standards of ethical behaviour required of directors, executives and employees - see below at Code of Ethics; and
- Share Trading Policy, setting out the policy and procedures for the sale and purchase of the Company’s securities by directors, executives and employees - see below at Share Trading Policy.
Principle 4 – Safeguard Integrity in Financial Reporting
For each financial year, the CEO and CFO have formally recorded that the Company’s financial reports present a true and fair view of the Company’s financial condition and operational results and are in accordance with accounting standards.
Given the size of the Board and the scope of the Company’s activities, the Board acts as the Audit Committee; with the functions exercised under the terms of reference of that Committee’s charter. As noted above, because the Company has no independent directors, the composition of the Audit Committee does not comply with this Principle in terms of composition.
The number of meetings of the Audit Committee held during each reporting period and the names of the attendees are set out in the relevant Directors’ Report.
The Audit Committee has a formal charter that incorporates its terms of reference. As required by that charter, the Board annually reviews the performance and ongoing independence of the (external) Auditors. The need (or not) for rotation of the lead partner or of the Auditors themselves forms part of that annual review.
Principle 5 – Make Timely and Balanced Disclosure
The Board has established policies and procedures designed to ensure compliance with all applicable Listing Rule disclosure requirements (and consequently continuous disclosure requirements under the Act) such that:
- all investors have equal and timely access to material information concerning the Company, including its financial position, performance, ownership and governance; and
- Company announcements are factual and presented in a clear and balanced way.
The Chairman, a Director or the Company Secretary authorises all disclosures necessary to ensure compliance with all applicable Listing Rule disclosure requirements.
Principle 6 – Respect the Rights of Shareholders
The Board has established a policy for communicating with the Company’s shareholders by:
- sending the Annual Report to shareholders;
- placing all shareholder related information and Stock Exchange announcements promptly onto the website in an accessible manner;
- ensuring shareholder participation in meetings by use of the Council’s guidelines for meetings and notices; and
- encouraging shareholders at the annual general meeting to question both the Directors (about the Company’s governance and business) and the Auditors (about the conduct of the audit and the content of the audit report).
Principle 7 – Recognise and Manage Risk
The Board is responsible for overseeing the effectiveness of risk management so as to:
- identify, assess, monitor and manage risk; and
- inform investors of the nature of, and material changes to, the Company’s risk profile.
The Company’s activities are currently centred on advancing its inherently high-in-risk exploration projects. Apart from geological risk, material business risks include financial, operational, environmental and technological risk - this is not an exhaustive list of risks faced by the Company. The Board considers the existing policies and procedures for risk oversight to be appropriate for the Company’s current stage of development.
At each major milestone of the Company’s projects, specific risk oversight and management policies are developed consistent with activities at that time. The Board categorises the various types of risks facing the Company by assessing their likelihood (as high, medium or low), gauging their consequences (as severe, significant or minor) and seeking to mitigate the related risk (by sharing risk with others (farmout or sale), raising of additional equity capital, employment of consultants, outsourcing, insurance or management process).
In relation to any financial reporting period, the Board receives formal assurance from the CEO and CFO that the declaration provided in accordance with section 295A of the Act is founded on a sound system of risk management and internal control and that the system is operating effectively in all material respects in relation to financial reporting risks.
Principle 8 – Remunerate Fairly and Responsibly
Given the size of the Board and the scope of the Company’s activities, the Board acts as the Remuneration Committee; with the functions exercised under the terms of reference of that Committee’s charter.
The Board reviews the remuneration packages of Directors and Executive Officers on an annual basis.
The Company’s policy for determining the nature and amount of emoluments of the Directors, non-executive and executive, is as follows:
- fees for non-executive directors are based on the demands and responsibilities of their role. In determining fees, regard is had for similar fee structures paid to non-executive directors in peer group companies;
- the remuneration structure for executive directors is determined having regard to industry practice, market trends and company performance;
- performance related incentive payments are based on share price performance targets but may also become based partly on other performance criteria established from time to time; and
- there is no provision of retiring allowances for directors.
The audited Remuneration Report (that is included in each Annual Report) details all forms of remuneration provided to the Directors during the relevant reporting period.
The Company has in place a Code of Ethics (“Code”) which is the framework of standards under which the Directors, Officers and Employees of the Company are expected to conduct their professional lives. The Code is not intended to prescribe an exhaustive list of acceptable and non-acceptable behaviour; rather it is intended to facilitate decisions that are consistent with the Company’s values, business goals and legal and policy obligations, thereby enhancing performance outcomes.
The Code is subject to annual review by the Board and is based around articles covering the areas of:
- Conflicts of interest;
- Gifts;
- Corporate opportunities;
- Confidentiality;
- Behaviour;
- Proper use of the Company’s assets and information;
- Compliance with laws and policies;
- Delegated authority;
- Additional director responsibilities;
- Information for the Board; and
- Reporting concerns.
In December 2010, the Company updated its formal Share Trading Policy (“Policy”) to comply with the new ASX requirements and lodged the Policy with ASX. The purpose of the policy document is to detail the policy and procedures for the sale and purchase of the Company’s securities by directors, executives and employees. The Policy covers:
- Dealing in securities and ‘inside information’;
- The primary drivers determining the Policy;
- Under what circumstances trading may occur;
- The circumstances of ‘Trading Lockouts’;
- Trading that is excluded from the Policy;
- Other prohibited conduct;
- The provision of notices given under the Policy;
- The form of application for trading approval; and
- The form of grant or refusal of trading approval.