To achieve this purpose, this policy requires that all directors, officers, employees and consultants* of Sipa should:

• not deal in Sipa's securities while in possession of 'Inside Information';
• not deal in Sipa's securities during specified Black-Out Periods (as set out below); and
• obtain clearance from the Company Secretary (or such other person designated in this policy) of any intended dealings in Sipa's securities.

Legally, insider trading is an offence which carries severe penalties, including imprisonment.  If you do not understand any aspect of this policy, you are encouraged to contact the Company Secretary.

2. Insider Trading

Any person, including a director, officer, employee or consultant of the Company, who has "Inside Information" cannot buy or sell the Company's securities at any time. If a director, officer, employee or consultant possesses Inside Information, the person must not:

• subscribe for, purchase or sell, or enter into an agreement to subscribe for, purchase or sell any securities in the Company;

• advise others or procure others to undertake such action; or

• either directly or indirectly pass on this kind of information to another person if they know, or ought reasonably to know, that this other person is likely to deal in the securities of the Company or procure another person to do so.

"Securities" include shares, options, derivatives and other financial products that can be traded on a financial market.

This prohibition applies at all times, irrespective of whether there is a trading Black-Out Period or otherwise.  The exercise of employee options is subject to the general prohibition against insider trading.

3. What is Inside Information

Inside Information is information which:

• is not generally available to the public; and
• if the information were generally available to the public, a reasonable person would expect it to have a material effect on the price or value of the securities of the Company.

Examples of material inside information may include (but are not limited to):

• Financial results

• Projections of future earnings or losses

• Project/drilling results

• News of a pending agreement of joint venture

• News of the disposition of a project

• New equity or placements

• Significant litigation exposure

• Significant corporate transaction, such as a proposed takeover bid or scheme of arrangement or other transactions affecting the Company's capital, such as a share buy-back

4. Trading Black-Out Periods

To reasonably ensure compliance with the Corporations Act and to protect the Company's reputation and integrity, all directors, officers, employees and consultants are prohibited from trading in Sipa shares during the Black-Out Periods.

The Black-Out Periods are:

• Quarterly results: The five trading days prior to the anticipated date of release of the Company's Quarterly results and 24 hours after the relevant announcement is made;

• Half yearly results: The five trading days prior to the anticipated date of release of the Company's half-yearly results and 24 hours after the relevant announcement is made;

• Annual Report: The five trading days prior to the anticipated date of release of the Company's Annual Report and 24 hours after the relevant announcement is made; and

• Drilling results: The five trading days prior to the anticipated date of release of any announcement containing drilling results of the Company and 24 hours after the relevant announcement is made.

In addition, the Company may advise that a Black-Out Period, other than the periods set out above, is in effect, such as if there are circumstances existing which are known to the Company and not yet disclosed to the public. 

It should be noted that outside of the Black-Out Periods, any person possessing Inside Information is subject to the general prohibition against Insider Trading (as explained in Section 1 above). 

In addition, no director, officer, employee or consultant can engage in any dealings in the Company's securities unless they have complied with the notification rules set out in Section 6 below.  

The Black-Out Periods will not restrict the exercise of employee options where the final date for the exercise of the option falls during a prohibited period and Sipa has been in an exceptionally long Black-Out Period or Sipa has had a number of consecutive Black-Out Periods and the restricted person could not reasonably have been expected to exercise it at a time when free to do so.  However, having exercised options, a director, officer, employee or consultant may be precluded from trading those shares if a Black-Out Period is in effect at the time.  The general prohibition against insider trading outlined in Section 2 above is still applicable to the exercise of employee options.

5. Exemption to trade during Black-Out Periods in exceptional circumstances

The Board may, in exceptional circumstances only, approve a director, officer, employee or consultant to trade in Sipa securities during a Black-Out Period.

The exceptional circumstances in which an exemption may be granted include where evidence is provided of severe financial hardship or a court order requiring the disposal of securities.