Submission to ASX Public Consultation Listing Rule Amendments Company Policies on

The issue of director share trading is central to maintaining the integrity of Australia’s capital markets. AICD believes that the case for a listing rule proposed by ASX has not been properly made out. In support of a less prescriptive approach and the positive impact of strong regulatory oversight and enforcement, the third quarter 2009 results from the ASX Market Supervision’s review of securities trading during “blackout” periods for possible contraventions of the publicly disclosed trading policies of listed entities shows a downward trend. If there must be a listing rule, AICD supports the approach taken by ASX since it gives boards the flexibility to determine the appropriate level of “internal regulation” of share trades by putting in place policies appropriate for the entity’s particular circumstances.