ASX listing rule 3.1 reads:

“Once an entity is or becomes aware of any information concerning it that a reasonable person would expect to have a material effect on the price or value of the entity’s securities, the entity must immediately tell ASX that information.”

In order to ensure the Company meets its obligations of timely disclosure of such information, the Company adheres to the following practices:

·  Immediate notification to ASX of information concerning the Company that a reasonable person would expect to have a material effect on the price or value of the Company’s securities as prescribed under listing rule 3.1, except where such information is not required to be disclosed in accordance with the exception provisions of the listing rules.

·  All information disclosed to ASX is promptly placed on the Company’s web site following receipt of confirmation from ASX.

·   Market speculation and rumours, whether unsubstantiated or not, have the potential to impact the Company. The Company’s general policy is to respond by advising that “ERG Limited does not respond to market rumour or speculation”. However, it may be necessary to make an announcement in certain circumstances and consider applying to ASX for a trading halt until an announcement is made.

The Company follows a program of half-yearly disclosures to the market on its financial and operational results. This is complemented by disclosures during the year as events occur.

·  All contact with external parties is on the basis that price sensitive information will not be discussed unless that particular information has been formally disclosed to the market via an ASX announcement.

·  The only Company officers authorised to speak on behalf of ERG Limited to institutional investors, stockbrokers and analysts are:

·  The Chairman; and

·  The Executive Directors

Any written materials containing new price sensitive information to be used in briefing media, institutional investors, stockbrokers and analysts are lodged with ASX prior to the briefing commencing. Upon confirmation of receipt by ASX, the briefing material is posted to the Company’s web site. Briefing materials may also include information that may not strictly be required under continuous disclosure requirements.

Media releases, financial reports and AGM speeches are also lodged with ASX and upon confirmation of receipt by ASX, these are posted to the Company’s web site.

To protect against inadvertent disclosure of price sensitive information, the Company imposes communication blackout periods for financial information between the end of financial reporting periods (31 December and 30 June) and the announcement of results to the market. During these periods the Company does not hold meetings or briefings to discuss financial information with individual investors, institutional investors, stockbrokers, analysts or media representatives unless such meetings or briefings are the subject of a specific announcement to the market via ASX.

Comments on expected earnings are confined to the Company’s financial reports or forecasts in a bidder’s statement or a prospectus, but any material change in a disclosed expectation is disclosed immediately via ASX.

The Company may host one-on-one briefings for institutional investors, stockbrokers and analysts to discuss information already released to the market via ASX and to provide background information to assist in their understanding of the Company’s businesses.

In hosting one-on-one briefings, the Company’s policy is to not disclose or discuss price sensitive information unless it has already been released to the market via ASX.

Generally, such interviews are conducted by the Chairman or the Executive Directors. If such a meeting results in an inadvertent disclosure of price sensitive information, then the information is immediately disclosed to ASX.

The Company responds to requests from media representatives for one-on-one briefings on a wide range of issues. In the course of these interviews, the Company’s policy is not to disclose or discuss price sensitive information unless it has already been disclosed to the market via ASX. Such interviews are generally conducted by the Chairman or the Executive Directors for corporate or financial issues while the Regional Managing Directors are authorised to speak to the media regarding issues specific to their local region.

In reviewing the content of these reports, the Company will correct factual inaccuracies or historical matters. The Company will not provide price sensitive information or earnings forecast guidance unless it has already been disclosed to the market via ASX.

For administrative convenience, the Company has nominated the Company Secretary as the person responsible for communication with ASX. In addition, the Company Secretary has responsibility for overseeing and coordinating disclosure of information to ASX and communicating with the Executive Directors in relation to continuous disclosure matters.

The Executive Directors are responsible for overseeing and coordinating disclosure of information to the media and to analysts, brokers and shareholders and communicating with the Company Secretary in relation to continuous disclosure matters.

Responsibility for reviewing disclosure issues arising from open or one-on-one briefings with either financial market or media representatives lies with the presenter. Each Manager of a business unit is responsible for:

· communicating with the Company Secretary in relation to possible continuous disclosure matters; and

· communicating with the Executive Directors in relation to media matters and investor relations matters concerning the business unit.

A continuous disclosure committee has been formed, comprising the following:

· Chairman;

· Executive Directors; and

· Company Secretary

A meeting of the committee may be convened from time to time to consider particular continuous disclosure issues.