Michael Hill updates securities trading policy

Michael Hill International Limited has released an updated securities trading policy, effective October 24, 2025, in compliance with ASX Listing Rule 12.10. The policy, available on the company's Investor Centre, outlines procedures for restricted persons to deal in company securities, requiring notification and clearance for most transactions, except for permitted dealings.

The policy emphasizes strict prohibitions on trading during blackout periods and when in possession of inside information, regardless of clearance status. Blackout periods include 10 days prior to the financial year-end and half-year end, concluding after the release of financial reports to the ASX, as well as periods following the release of price-sensitive information until its dissemination. The maximum penalties for insider trading under the Corporations Act include imprisonment for up to ten years or fines of up to 4,500 penalty units for individuals, and fines of up to 45,000 penalty units or 10% of annual turnover for corporations.

The updated policy also details clearance procedures, specifying who within Michael Hill is responsible for notifying and approving trades for different categories of restricted persons, such as the non-executive chairperson, executive chairperson, chief executive, and other directors. A clearance to deal, if granted, is valid for five business days, and the policy warns that such clearance does not absolve individuals of their legal obligations under insider trading laws.