Aussie Broadband : Securities Trading Policy

For personal use only

ASX Announcement

11 January 2022

Securities Trading Policy

In accordance with Listing Rule 12.10 a copy of the amended Aussie Broadband Securities Trading Policy is attached.

ENDS

Authorised for release by the Company Secretary.

Media enquiries contact Katrina Salhioui on 0448 110 962 Registry queries contact Link Market Services on 1300 554 474

For feedback and enquiries email [e-mail]

About Aussie Broadband Limited:

Aussie Broadband is an Australian owned and operated telecommunications company that was formed in 2008 and is based in Morwell Victoria, Australia.

The company's main focus is nbn™ (NBN) subscription plans and bundles to residential homes, small businesses, not-for-profits, corporate/enterprise and managed service providers.

As a licensed carrier, the company provides these services through a wholesale agreement with NBN Co, a mix of leased backhaul infrastructure from third parties and its own network equipment.

The company also offers a range of other telecommunications services including VOIP, mobile plans and handsets, entertainment bundles through its partnership with Fetch TV and connections through its own fibre, the Opticomm network and its white label platform.

For personal use only

Securities Trading Policy

Aussie Broadband Limited

Adopted by the Board on 26 November 2021.

Document version control:

Custodian	Company Secretary
Date previously approved by the Board	2 September 2020
Date of review	November 2021
Date of next scheduled review	November 2022
Legislative framework and regulatory	ASX Corporate Governance Principles and
compliance	Recommendations (4th edition)
Regulators	ASX
Aussie Broadband Limited | Securities Trading Policy - 26 November 2021	1

For personal use only

THIS POLICY IN SUMMARY

• No insider trading
• No trading during Blackout Periods
• No short term or speculative trading
• Restrictions on the use of derivatives
• Specified individuals must obtain prior written approval to deal and comply with a number of additional requirements
• Key terms used in this policy are set out on page 7 below

If you do not understand any part of this Policy, the summary of the law or how it applies to you, you should raise the matter with your manager or the Company Secretary before dealing with any securities covered by this Policy.

1. What is the purpose of this Policy?

Aussie Broadband is committed to ensuring that public confidence is maintained in the policies relating to the trading in its Securities.

This policy is intended to assist each Aussie Broadband Person to comply with their legal obligations relating to Securities trading, particularly while they are in possession of non- public information.

It has been prepared to meet the requirements of ASX Listing Rules 12.9 and 12.12.

2. Who does this Policy apply to?

'Aussie Broadband Person' includes all directors, officers and employees of Aussie Broadband and its controlled entities, and also any contractor and consultant whose terms of engagement by Aussie Broadband apply this policy to them.

3. What does this Policy apply to?

'Securities' includes Aussie Broadband's shares, notes, options, rights, debentures, and other securities.

It may also apply to other companies' Securities. This policy also applies to other companies' Securities if you have Inside Information.

If you are subject to a blacklist restriction applying to another company's Securities, you will be notified in writing by the Company Secretary or delegate.

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4. What are the consequences of breaching this policy?

If you breach insider trading laws, you could be fined, sued and/or imprisoned. Compliance with this policy, and Aussie Broadband's Code of Conduct, is also a condition of your employment, and breaches of this policy may also result in disciplinary action and/or summary termination of your appointment or employment.

5. Insider trading

It is an offence under the Corporations Act to trade using Inside Information, or communicate Inside Information to others who will, or are likely to, trade on the Inside Information.

This means that an Aussie Broadband Person who possesses Inside Information (whether of Aussie Broadband or another company) must not:

1. apply for, acquire or dispose of relevant Securities, or agree to do so;
2. permit, procure, encourage or induce another person (including e.g. a self- managed superannuation fund, company or family trust) to do any of the above things; or
3. directly or indirectly communicate the Inside Information to any other person, if the Aussie Broadband Person knows (or ought to know) that the other person may use the information to do any of the above things.

5.2 What is Inside Information?

'Inside Information' is information that is not generally available and, if it was generally available, a reasonable person would expect it to have a material effect on the price or value of the relevant Securities. In simple terms, this means information which might influence someone to decide whether or not to buy or sell the Securities.

Examples could include information relating to:

• financial performance (e.g., sales or profit of Aussie Broadband or a division);

• a material acquisition or disposal of assets, or takeover or merger;

• an actual or proposed dividend or change in dividend policy;

• an actual or proposed new share issue or change to capital structure;

• the entry into or termination of a material contract;

• a material claim or other unexpected liability; or

• a significant change in senior management.

Inside Information can include matters which are still in draft or not yet certain, and may include hints or rumours.

Information is not Inside Information if:

• it consists of a 'readily observable' matter;

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1. • it has been brought to the attention of investors by an ASX announcement and a reasonable period for its dissemination has elapsed since the announcement; or
   • it consists of observations, deductions, conclusions or inferences made or drawn from other generally available information.
2. Information can come from any source
   Inside Information does not have to be obtained from Aussie Broadband. It does not matter how or from where an Aussie Broadband Person obtains the information.
3. Conduct outside Australia is covered
   The Corporations Act prohibition applies to acts outside Australia, as well as in Australia.

6. No trading except during trading windows

There is a general prohibition in place meaning Aussie Broadband People must not trade, or procure another person to trade, in Aussie Broadband Securities given the heightened risk of actual or perceived insider trading. However the Company will declare "Trading Windows" where the general prohibition is lifted.

These Trading Windows are published on SharePoint and are available from the Company Secretary and Chairperson.

Trading Windows generally begin upon market open on the business day following the release to ASX of certain key announcements, namely:

• Quarter 1 and 3 market updates; and
• Half and Full Year results.

The Board may permit a Trading Window at other times of the year where it is of the view that the market is fully informed and there is no risk of actual or perceived insider trading.

Each Trading Window will close at market close on the day stipulated by the Company in its declaration of the Trading Window and will be published on the Wiki and will be available from the Company Secretary and Chairperson.

7. No trading with Inside Information

The Blackout Periods are a minimum requirement. If you possess Inside Information, you must not trade Securities whether or not a Blackout Period is operating. The responsibility to ensure you comply with insider trading laws falls to each person individually, and you should exercise care and judgement in deciding whether to trade Securities. If you are unsure, you should contact the Chairperson and Company Secretary.

No orders for the sale or purchase of Aussie Broadband Securities should be placed with a broker during a Blackout Period, and orders placed prior to the commencement of a Blackout Period must be cancelled if not executed before the Blackout Period commences. Provided an order was placed and executed prior to the commencement of a Blackout Period, it is not a breach of this policy if the transaction settles after the commencement of a Blackout Period.

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