VISION EYE INSTITUTE LTD 
By Securities trading policy
(January 2013)
Vision Eye Institute Limited
(ACN 098 890 816)
2
Securities trading policy
1) INTRODUCTION AND PURPOSE
This document sets out the policy covering restrictions on dealing in securities of Vision Eye Institute
Limited (Vision Eye Institute) and other entities in which Vision Eye Institute has an interest.
If you do not understand any part of this policy or the summary of the law, or how it applies to you, you should raise the matter with the Company Secretary before dealing with any security covered by this policy
This policy imposes basic trading restrictions on all employees of the Vision Eye Institute and its subsidiary companies who are in possession of inside information, and additional trading restrictions on the Key Management Personnel, including Directors and Senior Executives of Vision Eye Institute.
3) SECURITIES COVERED BY THIS POLICYa) This policy applies to trading in all Vision Eye Institute securities - this is a very broad concept and includes the following types of securities of Vision Eye Institute, and other entities in which Vision Eye Institute has an interest and referred to herein as "securities" including:
• Shares and options;
• Debentures (including bonds and notes);
• Interests in managed investment schemes, trusts and other financial products; and
• Derivatives of any of the above (including equity swaps, futures, hedges and exchange- traded or over-the-counter options) whether settled by cash or otherwise.
"Trading" includes:
• Acquiring or disposing of Vision Eye Institute securities on market or through an off market transaction;
• Acquiring or disposing of Vision Eye Institute securities in connection with margin lending or other security arrangements; and
• Stock lending arrangements affecting Vision Eye Institute securities.
b) The prohibition on insider trading also applies to securities issued by another company or entity if you have inside information (i.e. information which is not publicly known) about that company or entity - see paragraph 8(b). For this purpose "securities" covers the same range of shares, options, debentures, interests and derivatives as listed in paragraph a).
4) INSIDER TRADING LAWSa) If you have inside information which is not publicly known, it is a criminal offence for you to:
• Trade in securities;
• Advise or procure another person to trade in securities; or
• Pass on inside information to someone else - including colleagues, family or friends -
knowing (or where you should have reasonably known) that the other person will use that information to trade in, or procure someone else to trade in, securities.
Vision Eye Institute Limited Securities Trading Policy - January 2013
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b) This offence, called "insider trading", can subject you to criminal liability including large fines and/or imprisonment, and civil liability, which may include being sued by another party or Vision Eye Institute, for any loss suffered as a result of illegal trading.
5) CONFIDENTIAL INFORMATIONRelated to the above, you also have a duty of confidentiality to the Vision Eye Institute. You must not reveal any confidential information concerning the Vision Eye Institute, use that information in any way which may injure or cause loss to the Vision Eye Institute, or use that confidential information to gain an advantage for yourself.
6) WHAT IS "INSIDE INFORMATION"?a) "Inside information" is information that:
• Is not generally available; and
• If it were generally available, it would - or would be likely to - influence investors in deciding whether to buy or sell Vision Eye Institute securities.
b) It does not matter how you come to know the inside information (including whether you learn it in the course of carrying out your responsibilities or in passing in the corridor or in a lift or at a dinner party).
c) The financial impact of the information is important but strategic and other implications can be equally important in determining whether information is inside information. The definition of information is broad enough to include rumours, matters of supposition, intentions of a person (including Vision Eye Institute) and information which is insufficiently definite to warrant disclosure to the public.
The following list is illustrative only and is not exhaustive. Inside information could include;
a) A possible acquisition or sale of any assets or business by Vision Eye Institute;
b) The financial performance of Vision Eye Institute against the budgets or forecasts;
c) Senior Management or Board changes;
d) A proposed dividend;
e) A possible change in Vision Eye Institute's capital structure; or
f) Any possible claim against Vision Eye Institute or other unexpected liability.
a) If you possess inside information, you must not buy or sell Vision Eye Institute securities, advise or get others to do so or pass on the inside information to others. This prohibition applies regardless of how you learn of the information.
b) The prohibition on insider trading is not limited to information concerning Vision Eye Institute entities or to dealing in Vision Eye Institute securities. If you have inside information about another company or entity you must not deal in securities of that company or entity.
In addition to the general trading restrictions set out in this Policy that apply to all employees, additional restrictions on trading in Vision Eye Institute securities apply to the Key Management Personnel of Vision Eye Institute.
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9.1 Blackout Periods
Given the heightened risk of actual or perceived insider trading, in general, the Key Management Personnel including all directors and senior executives of Vision Eye Institute may not trade in Vision Eye Institute securities as follows:
• the period of 60 days immediately preceding the preliminary announcement of Vision Eye Institute's full year results or, if shorter, the period between the end of Vision Eye Institute's financial year and the preliminary announcement of the full year results; and
• the period between the end of Vision Eye Institute's half year and the publication of Vision
Eye Institute's half year results (together, Blackout Periods).
• When the Board of Vision Eye Institute is considering a matter that a reasonable person would expect to have a material effect on the price of Vision Eye Institute securities but information pertaining to the matter has not been disclosed because the Board has formed a view that a reasonable person would not expect such information to be disclosed, and the information is confidential and at least one or more of the following applies:
