Narrative summary

ListCo presentations concerning periodic financial information, Corporate Action(s) or ITOCOB events (“presentations”) and/or separate meetings with shareholders, the media or analysts (“meetings”) must be dealt with in the Information Policy.

Presentations and meetings must only be effected by authorised persons.

ListCo must ensure that authorised persons attend training concerning PSI/inside information principles contained in the JSE LR and FMA.

Authorised persons must be determined by ListCo.

Authorised persons must be briefed by ListCo prior to any presentation or meeting to ensure that no PSI is disclosed in the presentation or meeting.

Any meeting must be attended by at least two authorised persons.

Authorised persons must ensure that disclosure of PSI is not effected by body language actions.

Minutes of such meetings must be taken by one of the authorised persons.

Post a presentation or meeting, a review of the minutes is required by the ListCo to determine whether any PSI was inadvertently disclosed and, if so, immediate disclosure of same is required on SENS, and all policy principles applicable to PSI apply.

If any disclosure triggered a forecast, immediate compliance with the forecast JSE LR is required, resulting in communication with the JSE and announcement of the PSI and forecast information on SENS.

No expansion of previously disclosed information may be effected if it results in new PSI disclosures.

No corrections of analysts’ reports are allowed unless they are corrections of errors arising from previously published PSI.

All presentations of interim and financial year results (and any other periodic financial information presentations) require the relevant short form report to be published on SENS and placed on ListCo’s website before the presentation commences.

The actual presentation itself, which may contain PSI that is not included in the short form report, including forecast information, must be placed on ListCo’s website and must be referred to in the SENS announcement referred to above.

No PSI may be given out or discussed in any presentation that is not contained in the results and/or presentation published on SENS and on ListCo’s website.

Any unplanned PSI disclosures that are made during any presentation (such as answering questions, etc.) require immediate publication on SENS and if a forecast has been triggered, compliance with the JSE LR forecast requirements (detailed above) is required.

No “financial guidance” may be given to any person in a meeting or presentation regarding consensus analyst forecasts unless such “guidance” is supported by relevant PSI and/or forecast information already published on SENS and on ListCo’s website.

So-called “industry guidance” may only be given out if it does not “trigger” a profit forecast or new PSI and deals only with already known industry issues.

Any SENS announcement, whether voluntary or required by the JSE LR, must contain all known material facts concerning the subject matter of the announcement.

Internal briefings of employees should only contain public information unless the intention is to make such persons Insiders.

Any employees that are made Insiders must sign the insider register and comply with all PSI requirements.

ListCo must formulate a social media policy for ListCo and include same in its Information Policy.

If ListCo has its own social media platforms and disseminates information thereon, ListCo must appoint authorised persons to effect such disclosures in compliance with all principles contained in the Information Policy, noting that no social media platform is the equivalent of SENS disclosures regarding disclosure into the public domain.

A social media policy can be formulated to be very restrictive or less so. A very restrictive social media policy prohibits all access during working hours by employees to the various social media platforms such as Twitter, Facebook, Instagram, LinkedIn, etc.

Notwithstanding the general restrictiveness of the social media policy, the social media policy must prohibit any comment on any social media platform concerning any information relating to ListCo at any time i.e. inside or outside working hours.