SHARE AND OTHER FINANCIAL INSTRUMENTS TRADING POLICY

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					               SHARE AND OTHER FINANCIAL
              INSTRUMENTS TRADING POLICY
                         Policy No –BRD-8001
                           Version Number: 01.03

                      Implementation Date: 21/07/2009




Prepared By   Natalie Drake        6/07/09
Reviewed By   Duncan C Martin      6/07/09
Approved By   Board of Directors   21/07/09         Board Minutes
Introduction

                                                      e o e f h R c’sa s
                                                       r       ds
Directors and employees are encouraged to be long-t mhl ro T e okshr                   e
and other financial instruments. However, it is important that care is taken in the timing
of any acquisition or disposal of shares and other financial instruments in The Rock.
Directors and employees must not engage in conduct known as insider trading.

As well as serious civil and criminal liability arising from breaches of insider trading
laws, insider trading is also a serious breach of conditions of employment within The
Rock and will lead to disciplinary action up to and including dismissal.


Share and Other Financial Instruments Trading Philosophy

                                                                        e okshr
                                                                              e
Directors and employees, who have price-sensitive information about Th R c’sa s
 n o ef ac ln r et h hs tee l vib o t r m snts t s
      h n a su                 s c n
ad t ri ni i t m n w i i ’gnr laaalto e , utoueh   ay l e h s                  i
information to buy or sell those shares or other financial instruments.

Price-sensitive information must not be passed onto other people who are likely to deal or
trade in those shares or other financial instruments or who are likely to encourage others
to deal or trade in those shares or other financial instruments.


Rules for all Directors and Employees with inside information

Employees, including contractors, who have price-sensitive information, about a
company's (including The Rock and any of its related bodies corporate and customers of
The Rock) shares or other financial instruments, which isn't generally available to others:

      Must not apply for, buy or sell shares or other financial instruments of the
       company to which the inside information relates, either for themselves, or for
       another person

      Must not get another person (whether a family member, friend, associate,
       colleague, or your broker, investment adviser, private company or trust) to apply
       for, buy or sell the affected shares or other financial instruments for the employee,
       for another person or for themselves

      If an employee or a contractor has an arrangement with an agent to conduct
       discretionary trading on their behalf, they should ensure that the affected shares
       and other financial instruments are excluded from those shares, securities or other
       price sensitive products that the agent is authorised to buy and sell

      Must not, either directly or indirectly, give the inside information, or allow it to be
       given to another person who they know, or should know, would be likely to do
       any of the prohibited things described above



Share and Other Financial Instruments Trading Policy–Version 01.03            Page 2 of 6
      Must not apply for, acquire or dispose of, offer or agree to acquire or dispose of,
       or influence others (including family, associates, colleagues, private company or
       trustee) with regard to shares or other financial instruments issued by a customer
       of The Rock, where the employee or the contractor has access to inside
       information about that customer

      Must not communicate inside information to anybody who works for The Rock,
       whether as an employee or a contractor, except in accordance with the rules and
       policies of the relevant business division or as specifically directed by the
       Managing Director (or equivalent)

      Must not communicate inside information to anybody who works in The Rock,
                                                                        h m l e’ r
                                                                         e   o s
       whether as an employee or a contractor, if it does not relate to t e p ye o
        ot c r
          r os
       cn at ’job

      Must not get traders or distributors employed by The Rock to buy or sell
       securities or other price sensitive products on their behalf on the basis of inside
       information

      If an employee or a contractor liaises with industry analysts or business journalists
       working on the business activities of The Rock, they must not give them any
       inside information about The Rock, or confirm for them any suspicions or
       hunches which they may have, even if these hunches are based on their own
       research and analysis


Allowable Trading for Employees

Employees, other than Directors and senior management employees, may trade in The
  okshr ad t ri ni i r et tn t ,uj toh t re s f
            e        h n a su s
R c’sa s n o ef ac lnt m n aayi esb ct t o et m o    m        e       e h r
 h ply n t vrd g e r t n h a e p ye a ntr en h R c’
  i i             e r i sii a                       o
t s o c adh oe i n r tco t tn m l e m y ot d i T e oks              a
shares and other financial instruments whenever they have price-sensitive information
which is not generally available.

Employees, other than Directors and senior management employees, exposed to price-
sensitive information which is not generally available must gain formal approval (Form
HRM-800) from their departmental executive prior to undertaking any trading in The
  okshr o o ef ac ln r et The departmental executive may in turn
             e       h n a su s
R c’sa s r t ri ni i t m n .
refer the matter to the Managing Director (or equivalent) or his delegate for final
approval.

                                    iT e oks hr o o ef ac ln r et
                                                       e    h n a su s
All employees must enter their traden h R c’sa s r t ri ni i t m n
into the Employee Share Trading register held with the Company Secretary.




Share and Other Financial Instruments Trading Policy–Version 01.03           Page 3 of 6
Allowable Trading for Directors and Senior Management

Trading by Directors and senior management employees in shares or other financial
instruments of The Rock is not permitted during the non-trading window. Trading by
Directors and senior management employees in shares or other financial instruments of
The Rock is subject to the general rule that they must not trade in those shares or other
financial instruments whilst in possession of inside information.

Senior Management
Senior Management must gain formal approval (Form HRM-800) prior to trading in The
   c’sa s n o ef ac ln r et h uhh
            e       h n a su s r
Roks hr ad t ri ni i t m n t og t Managing Director (ore
equivalent). All approvals have a 14 day time limit. The trade must then be entered into
the Employee Share Trading register held with the Company Secretary.

Directors
                                                    0) r ror i iT e oks
                                                         o       an
Directors must gain formal approval (Form HRM-80 pi tt d gn h R c’
shares and other financial instruments through the Chairman of the Board. All approvals
have a 14 day time limit.

The Chairman of the Board must gain formal approval (Form HRM-800) prior to trading
n h R c’sa s n o ef ac ln r et h uhh hi a o t ui
                 e        h n a su s r
iT e okshr ad t ri ni i t m n t og t C a m n fh A d        e      r         e     t
Risk and Compliance Committee. This approval will have a 14 day time limit.

To enable The Rock to meet notify the ASX within 5 business days of a change in a
  i c r n r t n euie fh o pn,
   e o s te s               ts      e
Dr t ’i e s iscri o t C m ayas required under Listing Rules (listing
rule 3.19A.2), Directors must provide the relevant information to the Company Secretary
within two business days of the change. Notifications will also be tabled at meetings of
the Board.

                              l et d or i iT e oks
                               s e            an
The restrictions listed above a o x n t t d gn h R c’shares and other
financial instruments by spouses, partners, children, trusts, family companies and
nominees, where a Director or senior management employee may directly or indirectly
control or benefit from such action.

Non-Trading Window

Non-trading windows are calculated from the share or other financial instrument
transaction date, and commence:

    1 January and 1 July of each calendar year in preparation for the release of The
     Rock's half yearly and yearly results, or

    Immediately fl wn t B a ’dc i so
                     l g e            d     sn
                   o o i h or s eio toffer shares or other financial
     instruments in, or issued by, The Rock




Share and Other Financial Instruments Trading Policy–Version 01.03          Page 4 of 6
    Employee Share Schemes and other Capital Raisings

    The share and other financial instruments trading prohibition does not apply to:

        Applications for; and
        Acquisitions under those applications of,

     h R c’sa s r t ri ni i
                   e      h n a
    T e okshr o o ef ac lnstruments by employees, including senior
    management employees of The Rock or any of its related bodies corporate made under
    any employee share plans, option plans, or rights issue of shares.

    The prohibition will apply to any subsequent disposal by those employees of shares and
    other financial instruments in The Rock acquired under those employee share plans,
    option plans, or rights issue of shares.


    Definitions

      Information                        -   is any fact, matter or circumstance and includes
                                              matters of supposition (rumours or innuendo) or
                                              which are otherwise insufficiently definite to
                                              warrant being made known to the public and
                                              matters relating to intentions, or likely
                                              intentions, of a person

      Inside Information                 -   is not generally available but, if it were, a
                                              reasonable person would expect it to have
                                              material effect on the price or value of shares or
                                              other financial instruments

      Price-sensitive Information        -   will, or is likely to influence people, who
                                              commonly buy and sell shares or other financial
                                              instruments, in their decision on whether to buy
                                              or sell shares or other financial instruments
                                              (material effect)

      Generally available Information -      is readily observable or has been made known to
                                                ep h cm olt d iT e oks
                                                    e
                                              polw o o m nyr en h R c’   a
                                              shares or other financial instruments, and a
                                              reasonable period has elapsed to allow the
                                              information to be disseminated or is able to be
                                              deduced, concluded or inferred from those types
                                              of information



    Share and Other Financial Instruments Trading Policy–Version 01.03           Page 5 of 6
      Other Financial Instruments        -   include debt securities of The Rock, financial
                                              instruments issued or created over its securities
                                              by third parties, associated products which
                                              operate to limit the economic risk of a holding
                                               n h R c’scri n ay t ri ni
                                                                     ts
                                              iT e okseuie ad n o ef ac l           h n a
                                              instrument that can be traded on a financial
                                              market (that is, is tradeable on a stock exchange
                                              or other type of licensed financial market)




    Share and Other Financial Instruments Trading Policy–Version 01.03         Page 6 of 6

				
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