EBOS Group updates securities trading policy for regulatory compliance

The updated policy applies to directors and employees of EBOS Group Limited and its subsidiaries. It aims to align with the New Zealand Financial Markets Conduct Act 2013, the Australian Corporations Act 2001, NZX Listing Rules, and ASX Listing Rules. The policy details insider trading and market manipulation laws, emphasizing that compliance is a personal responsibility with significant penalties, including criminal liabilities. It defines "Material Information," "Information Insider," and "Restricted Person" to clarify trading prohibitions.

Restricted persons are prohibited from trading EBOS securities during blackout periods, specifically from January 1 to the close of trading on the business day after half-yearly results, and from July 1 to the close of trading on the business day after annual results. Exceptional circumstances may allow trading with prior chief executive approval. The policy also outlines rules against short-term trading, short selling, margin lending, and hedging unvested entitlements.

All trades by directors must be disclosed to NZX and ASX within five trading days. Senior managers have different disclosure timelines depending on the type of acquisition or disposal. The general counsel assists with disclosure notices, but ultimately, compliance is the individual's responsibility. The policy was last reviewed in November 2025 and will be reviewed every two years.