Novonix : Revised Securities Trading Policy

For personal use only

ASX ANNOUNCEMENT (ASX: NVX)

1 March 2022

Revised Securities Trading Policy

Please find attached a copy of the revised Securities Trading Policy lodged with the ASX in accordance with ASX Listing Rule 12.10. A copy of the Securities Trading Policy is available on the corporate governance section of the NOVONIX website at www.novonixgroup.com.

This announcement has been authorised for release by Company Secretary, Suzanne Yeates.

For NOVONIX Limited:

[e-mail](investors)

[e-mail](media)

NOVONIX Limited (ASX: NVX)

ACN 157 690 830

Level 38, 71 Eagle Street

Brisbane QLD 4000

AUSTRALIA

For personal use only

Securities trading policy

NOVONIX Limited ACN 157 690 830

For personal use only

Table of contents

Contents
Table of contents....................................................................................................................	2
Securities trading policy ..........................................................................................................	3
1	Who does this Policy apply to......................................................................................	3
2	Which securities does this Policy apply to.....................................................................	3
3	Prohibition on insider trading - applies to all Company Personnel ...................................	4
4	Restrictions on dealing in securities - applies to Restricted Persons only.........................	4
5	Authorised Trading for Restricted Persons....................................................................	5
6	Notification of trades..................................................................................................	7
7	Restrictions on certain arrangements over NOVONIX Securities......................................	8
8	Securities to which this Policy does not apply ...............................................................	9
9	Securities in other companies .....................................................................................	9
10	Escrow......................................................................................................................	9
11	Breach ....................................................................................................................	10
12	Who to contact........................................................................................................	10
13	Review....................................................................................................................	10
14	Glossary..................................................................................................................	11

Securities trading policy

For personal use only

Securities trading policy

NOVONIX Limited ACN 157 690 830

1 Who does this Policy apply to

1. This Policy applies to all Company Personnel.
2. Section 4 of this Policy applies to:
3. 1. all Directors and other Key Management Personnel (including the CEO);
   2. all direct reports to Key Management Personnel;
   3. any other personnel designated by the General Counsel of the Company from time to time (collectively with paragraphs (a) and (b), Relevant Personnel); and
   4. closely related parties (as that term is defined in the Corporations Act)1 of all Relevant Personnel,

and the persons listed above are called Restricted Persons.

1. Relevant Personnel are Company Personnel who may regularly have access to sensitive Company information due to their position within the Company Group. The General Counsel of the Company maintains a list of Restricted Persons and will notify Restricted Persons of their designation.
2. Where this Policy requires a Restricted Person to do something (e.g., obtain clearance in accordance with Section 6), that person must also do so for their closely related parties.

2 Which securities does this Policy apply to

2.1 This Policy applies to all securities issued by NOVONIX of any kind, including:

1. ordinary or preference shares;
2. debentures;
3. convertible notes;
4. bonds;
5. options;
6. American depositary shares;
7. interests in managed investment schemes, trusts and other financial products;
8. any derivatives of those securities, including equity swaps, futures, hedges and exchange-traded or over-the-counter options, whether settled by cash or otherwise; and
9. any other financial products that are able to be traded on a financial market.

1 A 'closely related party' of a person (the Person) includes that Person's spouse, child, spouse's child, a dependent of the Person or Person's spouse, any other family member of the Person who is in a position of influence over, or may be influenced by, the Person, or a company controlled by the Person.

Securities trading policy

3

For personal use only

1. For the purposes of this Policy, all the securities referred to above are called NOVONIX Securities.
2. The circumstances in which this Policy does not apply are set out in section 8.

3 Prohibition on insider trading - applies to all Company Personnel

Prohibition on insider trading

1. No Company Personnel may, while in possession of inside information concerning the Company, in breach of the Corporations Act:
2. 1. buy or sell any NOVONIX Securities at any time;
   2. procure another person to deal in NOVONIX Securities in any way; or
   3. pass on any inside information concerning the Company to another person for that person's own personal gain by dealing in NOVONIX Securities in any way.
3. All Company Personnel are prohibited from dealing in the securities of outside companies about which they acquire inside information through their position with the Company Group.
4. Sections 3.5 and 3.6 of this Policy outlines what constitutes 'inside information'.
5. If you deal in NOVONIX Securities while you have inside information, not only are you in breach of this Policy, but you may also be in breach of the insider trading provisions of the Corporation Act, which is a criminal offence.
   What is inside information
6. Inside information is information that is not generally available, and which, if it were generally available:
7. 1. a reasonable person would expect it would have a material effect on the price or value of NOVONIX Securities; or
   2. would, or would be likely to, influence persons who commonly invest in securities in deciding whether to acquire or dispose of NOVONIX Securities.
8. Information is considered 'generally available' if it is readily observable, or if it has been made known in a manner likely to bring it to the attention of persons who commonly invest in securities of the relevant type.
   Speculative Trading
9. If you are a Company Personnel, you must not trade in NOVONIX Securities for short term or speculative gain. Short-term trading includes buying and selling securities on market within a range of a few days to a few weeks.

4 Restrictions on dealing in securities - applies to Restricted Persons only

4.1 If you are a Restricted Person, you must not deal in NOVONIX Securities except during a Trading Window or unless permitted to do so under Section 5.

Securities trading policy

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