Trading Policy

For personal use only

Raiz Invest Limited

Trading Policy

Raiz Invest Limited ACN 615 510 177 ("Company")

Date 9 November 2021

1

For personal use only

1 Purpose

Scope

1. This policy summarises the laws relating to insider trading and sets out Raiz Invest Limited's ("Company") trading policy on buying and selling any securities of the Company that are able to be traded on a financial market ("Company's Securities").
   Who does this policy apply to?
2. This policy applies as follows:
3. 1. part 2 (insider trading laws) and part 7 (confidentiality) apply to everyone (including all employees, contractors, family, authorised representatives under Instreet Investment Limited's (the responsible entity of the Raiz Invest Australia Fund) Australian Financial Services Licence and associates);
   2. parts 3 to 6 (trading policy) apply to all directors, officers, personnel and authorised representatives under the Instreet Investment Limited (the responsible entity of the Raiz Invest Australia Fund) Australian Financial Services Licence, and any other person designated by the board of directors ("Board") from time to time (each a "Designated Person"); and
   3. paragraphs 3.12 and 3.13 (associates) apply our trading policy to the family and associates of Designated Persons as specified in those paragraphs.

Further advice

1.3 If you do not understand any aspect of this trading policy or are uncertain whether it applies to you or your family or associates, please seek your own legal or financial advice before dealing in the Company's Securities.

2 Insider trading prohibitions in the Corporations Act

What are the insider trading prohibitions?

1. Under the Corporations Act 2001 (Cth) ("Corporations Act"), if you have Inside Information
   (as defined in the Corporations Act and summarised in paragraphs 2.5 to 2.8 below) relating to the Company it is illegal for you to:
2. 1. deal in (that is, apply for, acquire or dispose of) the Company's Securities or enter into an agreement to do so; or
   2. procure another person to apply for, acquire or dispose of the Company's Securities or enter into an agreement to do so; or
   3. directly or indirectly communicate, or cause to be communicated, that information to any other person if you know, or ought reasonably to know, that the person would or would be likely to use the information to engage in the activities specified in paragraphs (a) or (b) above.
3. These prohibitions also apply to the application for, grant, exercise or transfer of an option over the Company's Securities, and to the securities of other entities if you possess Inside
   Information about those entities.
4. It does not matter how or in what capacity you become aware of the Inside Information. It does not have to be obtained from the Company to constitute Inside Information.

2

For personal use only

1. You cannot avoid the insider trading prohibition by arranging for a member of your family or a friend to deal in the Company's Securities nor may you give "tips" concerning Inside Information relating to the Company to others.
   These prohibitions apply to everyone (not just Designated Persons) at all times.What is inside information?
2. "Inside Information" is information relating to the Company which is not generally available but, if the information were generally available, would be likely to have a material effect on the price or value of the Company's Securities.
3. Inside Information can include matters of speculation or supposition and matters relating to intentions or likely intentions of a person.
4. Information is regarded as being likely to have a material effect if it would, or would be likely to, influence persons who commonly invest in securities or other traded financial products in deciding whether or not to deal in the Company's Securities.
5. Examples of Inside Information could be:
6. 1. the financial performance of the Company against its budget or any market guidance;
   2. changes in the Company's actual or anticipated financial condition or business performance;
   3. changes in the capital structure of the Company, including proposals to raise additional equity or borrowings;
   4. proposed changes in the nature of the business of the Company;
   5. changes to the Board or significant changes in key management personnel;
   6. an undisclosed significant change in the Company's market share;
   7. likely or actual entry into, or loss of, a material contract;
   8. material acquisitions or sales of assets by the Company;
   9. a proposed dividend or other distribution or a change in dividend policy; or
   10. a material claim against the Company or other unexpected liability.

When is information generally available?

1. Information is generally available if:
2. 1. it consists of readily observable matters or deductions;
   2. it has been brought to the attention of investors through an announcement to ASX
      Limited ("ASX") or otherwise similarly brought to the attention of investors who commonly invest in securities, and a reasonable period has elapsed since it was announced or brought to investors' attention; or
   3. it consists of deductions, conclusions or inferences made or drawn from information referred to in paragraphs (a) or (b) above.
3. Examples of possible readily observable matters are:
4. 1. a change in legislation which will affect the Company's ability to make certain types of investments; or
   2. a severe downturn in global securities markets.

3

For personal use only

Penalties

1. Breach of the insider trading laws may subject you to:
2. 1. criminal liability - penalties include heavy fines and imprisonment;
   2. civil liability - you can be sued by another party or the Company for any loss suffered as a result of illegal trading activities;
   3. civil penalty provisions - the Australian Securities and Investments Commission
      ("ASIC") may seek civil penalties against you and may even seek a court order that you be disqualified from managing a corporation.
3. Breach of the law, this policy, or both, will also be regarded by the Company as serious misconduct which may lead to disciplinary action or dismissal. In some circumstances, the Company may also be obliged to notify regulatory and/or criminal authorities of a breach of this policy.
   Insider trading and securities in other companies
4. While in general you are free to deal in securities of other listed companies, the insider trading laws prohibit dealings not only in the Company's Securities but also in the securities of other listed companies in respect of which you possess inside information.
5. If you are aware of inside information in respect of another company, you should not trade or deal in the securities of that company. For example, where you are aware that the Company is about to sign a major agreement with another company, you should not buy securities in either the Company or the other company.
6. The Board may extend this policy by specifying restrictions from dealing in securities of other specified companies with which the Company may have a close relationship.

3 No Dealing in Prohibited Periods

Closed and prohibited periods

1. Designated Persons must not deal in the Company's Securities during the following prohibited periods (except in accordance with this policy):
2. 1. the following closed periods:
   2. 1. from the day after the half year end (i.e. 1 January) to the close of trading on the business day after the Company's half yearly results are announced to ASX;
      2. from the day after the financial year end (i.e. 1 July) to the close of trading on the business day after the Company's annual results are announced to
         ASX;
      3. from 28 days before, to the close of trading on the business day after, the
         Company's annual general meeting; and
      4. from 28 days before a prospectus or similar disclosure document is lodged by the Company with ASX; and
   3. any extension to a closed period, and any additional period, as specified by the Board,
      ("Prohibited Periods").
3. Designated Persons may deal in the Company's Securities at other times subject to complying with insider trading prohibitions (see part 2 above) and the requirements of this policy.

4

For personal use only

Prior notification

3.3 If a Designated Person proposes to deal in the Company's Securities (including entering into an agreement to deal) during a Prohibited Period they must first provide:

1. written notice of their intention to the Company Secretary (or another person, as notified to the relevant Designated Person) ("Notification Officer"); and
2. written confirmation that they are not in possession of Inside Information,

in the form of the template in Appendix A Part A.

1. The relevant Notification Officer may appoint a delegate to act on his or her behalf in the case of temporary absence.
   Clearance
2. Before dealing in the Company's Securities, the Designated Person must receive a written clearance in the form of the template at Appendix A Part B signed by the Notification Officer.
3. A clearance expires five business days from its date, unless it specifies a different expiry date.
4. A clearance to trade confirms that the proposed dealing by the Designed Person is within the terms of the trading policy but does not otherwise constitute approval or endorsement by the Company or the Notification Officer for the proposed dealing. Even if a clearance is granted, a Designated Person remains personally responsible for assessing whether the insider trading prohibitions apply to them.
5. A register of notifications and clearances is to be kept by the Company Secretary.
   Notification of dealing
6. In addition to providing prior notification and seeking clearance under paragraph 3.3, Designated Persons must confirm in writing to the relevant Notification Officer, within three business days from when the dealing in the Company's Securities has occurred, the number of the Company's Securities affected and the relevant parties to the dealing.
7. A register of Designated Persons' interests in the Company's securities is to be kept by the
   Company Secretary.
   Securities of other entities
8. The Board may extend this policy by specifying that Designated Persons are also restricted from dealing in the securities of other specified entities with which the Company may have a close relationship.
   Associates
9. This policy also applies to associates of Designated Persons. A Designated Person must communicate on behalf of their associate with the Notification Officer for the purposes of this policy.
10. "Associates" of a Designated Person includes their family members, trusts, companies, nominees and other persons over whom a Designated Person has, or may be expected to have, investment control or influence. If you are in doubt as to whether a person is an associate, you should contact the Company Secretary who will make a determination on the issue.

4 Exceptional Circumstances

4.1 A Designated Person may request, and the Notification Officer may give, prior confirmation for the Designated Person to:

1. deal in the Company's Securities during a Prohibited Period; or

5