Trigg Mining : Updated Trading Policy

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22 FEB 2022

ASX: TMG

Updated Trading Policy

Trigg Mining Limited (ASX: TMG) (Trigg or the Company) advises that the Board of Directors has adopted an updated Trading Policy.

In accordance with Listing Rule 12.10 a copy of the revised Trading Policy follows this announcement. A copy of the Trading Policy is available within the Corporate Governance Plan section on the Company's website.

This announcement was authorised to be given to ASX by the Board of Directors of Trigg Mining Limited.

Keren Paterson

Managing Director & CEO

Trigg Mining Limited

For more information please contact:

Keren Paterson	Nicholas Read
Managing Director & CEO	Investor and Media Relations
Trigg Mining Limited	Read Corporate
[phone]	[phone]
[e-mail]	[e-mail]

Level 1, Office E, 1139 Hay Street, West Perth, Western Australia 6005 TRIGGMINING.COM.AU [phone] [e-mail]

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SCHEDULE 9 - TRADING POLICY

1. INTRODUCTION
   These guidelines set out the policy on the sale and purchase of securities in the Company by its Employees. Employees are encouraged to be long-term holders of the Company's securities. However, it is important that care is taken in the timing of any purchase or sale of such securities.
   The purpose of these guidelines is to assist Employees to avoid conduct known as 'insider trading'. In some respects, the Company's policy extends beyond the strict requirements of the Corporations Act 2001 (Cth).
2. APPLICATION OF THIS POLICY
   This Policy applies to anyone who is employed by or works for the Company, including employees (whether permanent, part-time, fixed term or temporary), contractors, consultants, secondees, officers and directors (collectively referred to as Employees in this Policy).
3. WHAT TYPES OF TRANSACTIONS ARE COVERED BY THIS POLICY?
   This policy applies to both the sale and purchase of any securities of the Company and its subsidiaries on issue from time to time.
4. WHAT IS INSIDER TRADING?

1. Prohibition
   Insider trading is a criminal offence. It may also result in civil liability. In broad terms, a person will be guilty of insider trading if:
2. 1. that person possesses information, which is not generally available to the market and if it were generally available to the market, would be likely to have a material effect on the price or value of the Company's securities (ie information that is 'price sensitive'); and
   2. that person:
   3. 1. buys or sells securities in the Company; or
      2. procures someone else to buy or sell securities in the Company; or
      3. passes on that information to a third party where that person knows, or ought reasonably to know, that the third party would be likely to buy or sell the securities or procure someone else to buy or sell the securities of the Company.
3. Examples
   To illustrate the prohibition described above, the following are possible examples of price sensitive information which, if made available to the market, may be likely to materially affect the price of the Company's securities:

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1. 1. the Company considering a major acquisition or disposal;
   2. the threat of major litigation against the Company;
   3. the Company's revenue and profit or loss results materially exceeding (or falling short of) the market's expectations;
   4. a material change in debt, liquidity or cash flow;
   5. a significant new development proposal (e.g. new product or technology);
   6. the grant or loss of a major contract;
   7. a management or business restructuring proposal;
   8. a share issue proposal;
   9. an agreement or option to acquire an interest in a mining tenement, or to enter into a joint venture or farm-in or farm-out arrangement in relation to a mining tenement;
   10. significant discoveries, exploration results, or changes in reserve/resource estimates from mining tenements in which the Company has an interest; and
   11. giving or receiving a notice of intention to make a takeover.
2. Dealing through third parties
   The insider trading prohibition extends to dealings by individuals through nominees, agents or other associates, such as family members, family trusts and family companies (referred to as "Associates" in these guidelines).
3. Information however obtained
   It does not matter how or where the person obtains the information - it does not have to be obtained from the Company to constitute inside information.
4. Employee incentive schemes
   The prohibition does not apply to acquisitions of shares or options by employees made under employee share or option schemes, nor does it apply to the acquisition of shares as a result of the exercise of options under an employee option scheme. However, the prohibition does apply to the sale of shares acquired under an employee share scheme and also to the sale of shares acquired following the exercise of an option granted under an employee option scheme.

5. PROHIBITION ON DERIVATIVES AND HEDGING ARRANGEMENTS OVER COMPANY SECURITIES

Directors and Employees and other participants in employee incentive schemes of the Company are not permitted to use, at any time, derivatives or hedging arrangements that operate or are intended to operate to limit the economic risk of security holdings over unvested Company securities.

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6. GUIDELINES FOR TRADING IN THE COMPANY'S SECURITIES

6.1 General rule

Directors and Employees must not, except in exceptional circumstances, deal in securities of the Company during the following periods:

1. two weeks prior to, and 48 hours after the release of the Company's Annual Report to the ASX (inclusive);
2. two weeks prior to, and 48 hours after the release of the Company's Half Year Report to the ASX (inclusive);
3. 1 April and the day after the release of the Company's Quarterly Report to the ASX (if applicable) (inclusive); and
4. 1 October and the day after the release of the Company's Quarterly Report (if applicable) (inclusive),

(together the Closed Periods).

The Company may at its discretion vary this rule in relation to a particular Closed Period by general announcement to all Directors and Employees either before or during the Closed Periods. However, if a Directors and Employees is in possession of price sensitive information which is not generally available to the market, then he or she must not deal in the Company's securities at any time it is in possession of such information.

1. No short-term trading in the Company's securities
   Directors and Employees should never engage in short-term trading of the Company's securities except for the exercise of options where the shares will be sold shortly thereafter.
2. Securities in other companies
   Buying and selling securities of other companies with which the Company may be dealing is prohibited where an individual possesses information which is not generally available to the market and is 'price sensitive'. For example, where an individual is aware that the Company is about to sign a major agreement with another company, they should not buy securities in either the Company or the other company.
3. Exceptions
4. 1. Directors and Employees may at any time:
   2. 1. acquire ordinary shares in the Company by conversion of securities giving a right of conversion to ordinary shares;
      2. acquire Company securities under a bonus issue made to all holders of securities of the same class;
      3. acquire Company securities under a dividend reinvestment, or top- up plan that is available to all holders or securities of the same class;

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1. acquire, or agree to acquire or exercise options under an employee incentive scheme (as that term is defined in the ASX Listing Rules);
2. withdraw ordinary shares in the Company held on behalf of the Directors and Employees in an employee incentive scheme (as that term is defined in the ASX Listing Rules) where the withdrawal is permitted by the rules of that scheme;
3. acquire ordinary shares in the Company as a result of the exercise of options held under an employee option scheme;
4. transfer securities of the Company already held into a superannuation fund or other saving scheme in which the restricted person is a beneficiary;
5. make an investment in, or trade in units of, a fund or other scheme (other than a scheme only investing in the securities of the Company) where the assets of the fund or other scheme are invested at the discretion of a third party;
6. where a restricted person is a trustee, trade in the securities of the Company by that trust, provided the restricted person is not a beneficiary of the trust and any decision to trade during a prohibited period is taken by the other trustees or by the investment managers independently of the restricted person;
7. undertake to accept, or accept, a takeover offer;
8. trade under an offer or invitation made to all or most of the security holders, such as a rights issue, a security purchase plan, a dividend or distribution reinvestment plan and an equal access buy-back, where the plan that determines the timing and structure of the offer has been approved by the Board. This includes decisions relating to whether or not to take up the entitlements and the sale of entitlements required to provide for the take up of the balance of entitlements under a renounceable pro rota issue;
9. dispose of securities of the Company resulting from a secured lender exercising their rights, for example, under a margin lending arrangement;
10. exercise (but not sell securities following exercise) an option or a right under an employee incentive scheme, or convert a convertible security, where the final date for the exercise of the option or right, or the conversion of the security, falls during a prohibited period or the Company has had a number of consecutive prohibited periods and the restricted person could not reasonably have been expected to exercise it at a time when free to do so; or

1. trade under a non-discretionary trading plan for which prior written clearance has been provided in accordance with procedures set out in this Policy.