Share Trading Policy

SHARE TRADING POLICY

The Company has adopted a policy that imposes restrictions on Directors and employees trading in the securities of the Company. The restrictions have been imposed to prevent trading in contravention of the insider trading provision of the Corporation Act.

The key aspects of the policy are:

(a) no Officer or employee or any entities controlled by them is allowed to trade in the securities of the Company without first receiving approval from the Chairman and a suitable trading window is identified and communicated by the Managing Director;

(b) all Officers and employees are to formally notify the Company Secretary of their beneficial shareholdings in the Company and any changes to this within 2 days of such change occurring. The Company Secretary will maintain a register of interests in the Company held by Directors and employees;

(c) no Officer or employee or any entities controlled by them is allowed to engage in the business of active dealing in the Company’s securities;

(d) an Officer, employee or any entities controlled by them must not trade at any time when they are in possession of information which if generally available would materially affect the price or value of the Company’s securities or at any time for a period of 2 trading days following a public announcement in relation to the matter; and

(e) No officer or employee or any entity controlled by them is allowed to engage in buying or selling securities in any company with which Cooper Energy is involved operationally or corporately without conforming with the processes applicable in (a) to (d) above.

Review of the Policy

This Policy will be formally reviewed by the Board each year.