Shriro : Revised Securities Dealing Policy

Lisa Jones Company Secretary [phone] [e-mail]

22 December 2021

onlyASX ANNOUNCEMENT Revised Securities Dealing Policy

In accordance with ASX Listing Rule 12.10, Shriro Holdings Limited advises that it has amended its Securities Dealing Policy (Policy) with effect from 15 December 2021.

A copy of the revised Policy is attached for release to the market.

useThis ASX Announcement was approved and authorised for release by the Company Secretary following Board approval of the revised Policy.

For more information, contact:

Tim Hargreaves

personalCEO

[phone] [e-mail]

ABOUT SHRIRO

The Group is a leading kitchen appliances and consumer products marketing and distribution group operating in Australia and New Zealand. The Group markets and distributes an extensive range of company-owned brands (including Omega, Robinhood, Everdure and Omega Altise) and third party owned brands (such as Casio, Blanco and Pioneer). Products include calculators, watches, musical instruments, audio products, kitchen appliances, sinks & taps, laundry

p oducts, consumer electronics, car audio, amplifiers, professional DJ, Hi-Fi/speakers, gas heaters, gas barbeques, charcoal barbeques, electric heaters and cooling products.

For

SHRIRO HOLDINGS LIMITED

Level 7, 67 Albert Avenue, Chatswood, NSW, 2067 Australia Tel: [phone] Fax: [phone]

Website: www.shriro.com.au ACN 605 279 329

For personal use only

Securities Dealing Policy

Shriro Holdings Limited

ACN 605279329

Adopted by the Board on 15 December 2021

For personal use only

Contents

1	What is this Policy about?	3
2	Who must comply with this Policy?	3
3	Restrictions applying to all Employees	3
	3.1	No dealing while in possession of Inside Information ..........................................	3
	3.2	The Front Page Test ............................................................................................	4
	3.3	No short-term or speculative dealing ...................................................................	4
	3.4	Hedging of Company securities ...........................................................................	4
	3.5	Dealing in other companies' securities ................................................................	5
4	Additional restrictions applying to Restricted Persons	5
	4.1	No dealing in blackout periods.............................................................................	5
	4.2	Exceptional circumstances ..................................................................................	5
	4.3	Heading Approval required for dealing outside blackout periods ........................	5
	4.4	Written request process .......................................................................................	6
	4.5	Margin lending arrangements ..............................................................................	6
	4.6	Directors - confirmation of trade required ...........................................................	6
	4.7	Connected Persons .............................................................................................	7
5	Excluded Dealings	7
6	What are the rules about insider trading?	8
7	What happens if this Policy is breached?	8
8	Who should I contact?	8

For personal use only

Securities Dealing Policy

1 What is this Policy about?

The purpose of this Policy is to:

• ensure that public confidence is maintained in the reputation of the Company and its related bodies corporate (Group), directors and employees of the Group and in the trading of the Company's securities;
• outline the policy and procedures that apply to directors and employees when dealing in the Company's securities; and
• recognise that some types of dealing in securities are prohibited by law.

The Company will take a substance over form approach and will have regard to the intent and spirit of this Policy when applying and enforcing it.

2 Who must comply with this Policy?

This Policy applies to all Directors of the Company and Group employees (collectively, Employees).

Certain parts of this Policy apply only to Restricted Persons who, for the purposes of this Policy, are:

• Directors;
• other key management personnel of the Company and direct reports to the CEO (Senior Executives); and
• other persons who regularly possess inside information and who have been advised by the Company Secretary that they are subject to special restrictions under this Policy (Nominated Employees).

Restricted Persons must also take steps in relation to dealings by their Connected Persons. See section 4.7 for further information in relation to Connected Persons.

3 Restrictions applying to all Employees

3.1 No dealing while in possession of Inside Information

Employees must not deal in the Company's securities if:

• they are aware of Inside Information in relation to the Company; or
• the Company has notified Employees that they must not deal in securities (either for a specified period, or until the Company gives further notice).

Shriro Holdings Limited
SECURITIES DEALING POLICY	Page 3

For personal use only

Inside Information is information that:

• is not generally available to the market; and
• if it were generally available to the market, a reasonable person would expect it to have a material effect (upwards or downwards) on the price or value of a security.

Inside Information may include matters of supposition, matters that are not yet certain and matters relating to a person's intentions.

Section 6 contains further details regarding the scope of the insider trading laws.

3.2 The Front Page Test

It is important that public confidence in the Group is maintained. It would be damaging to the Group's reputation if the market or the general public perceived that Employees might be taking advantage of their position in the Group to make financial gains (by dealing in securities on the basis of Inside Information).

As a guiding principle, Employees should ask themselves:

If the market was aware of all the current circumstances, could I be perceived to be taking advantage of my position in an inappropriate way? How would it look if the transaction were reported on the front page of the newspaper? (The Front Page Test)

If the Employee is unsure, he or she should consult the Company Secretary.

Where any approval is required for a dealing under this Policy, approval will not be granted where the dealing would not satisfy the Front Page Test.

3.3 No short-term or speculative dealing

Employees must not deal in the Company's securities on a short-term trading basis. Short-term trading includes buying and selling securities on market within a 3 month period, and entering into other short term dealings (for example, forward contracts).

Selling shares received on vesting of entitlements under an employee, executive or director equity plan within 3 months of the vesting date is not a short-term dealing.

Employees must not deal in the Company's securities on a speculative basis, including short-selling. Short selling involves borrowing and selling securities in the hope that they can be bought back at a lower price in the future to close out the short position at a profit.

3.4 Hedging of Company securities

Hedging includes entering into any arrangements that operate to limit the economic risk associated with holding the Company's securities.

Company securities acquired under an employee, executive or director equity plan operated by the Company must never be hedged prior to vesting.

Company securities must never be hedged while they are subject to a holding lock or restriction on dealing under the terms of an employee, executive or director equity plan operated by the Company.

Shriro Holdings Limited
SECURITIES DEALING POLICY	Page 4