Tatts Group is committed to complying with its continuous disclosure obligations under the Corporations Act and the ASX Listing Rules and releasing relevant information to the market and shareholders in a timely and direct manner.

The Board has adopted a policy which is designed to ensure that, information which is not generally available and which may have a material effect on the price or value of the Company’s securities (price sensitive information) is identified and appropriately considered by the Directors and senior executives for disclosure to the market. The policy also sets out procedures which must be followed in relation to releasing announcements to the market and discussion with analysts, the media or shareholders.

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The Board has adopted a policy which outlines the steps which Directors and employees should take if they have a genuine suspicion of improper conduct (as described in the policy) regarding the Group's activities.

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The Board has adopted a policy which sets out the circumstances in which Directors and employees may deal in Company securities and enter into transactions in products which operate to limit the economic risk of holding the Company’s securities. The policy was reviewed during the reporting period.

An overriding principle of the policy is that Directors and employees who possess price sensitive information must not deal in Company securities or enter into any transactions in risk limiting products. The policy specifies ‘blackout periods’ during which Directors and employees must not deal in Company securities or enter into transactions in risk limiting products, regardless of whether or not they are in possession of price sensitive information.

The policy has limited exceptions (e.g. acquisitions under employee equity plans). As a result of the review the policy has been amended to remove the ‘trading windows’. It was considered the trading windows were unnecessarily restrictive and the better approach is to ensure employees and Directors comply with the insider trading obligations contained in the Corporations Act. Additional safeguards exist in respect of Directors and senior executives who have notification requirements before they can trade.

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The Company offers eligible employees the opportunity to participate in equity based incentive plans as part of their remuneration package. The Company has a hedging policy which clarifies the Company’s position in respect to the Long Term Incentive Plan (LTIP).

The policy states that eligible employees may not enter into any contract, arrangement or transaction which is designed or intended to hedge or otherwise limit the individual’s economic exposure to Tatts Group shares which are subject to an unvested award granted under the LTIP or other equity based plan. Once vested the employee can deal with those shares, subject to the Company’s share trading policy.

However, the policy does not restrict or prevent employees from dealing with shares in which they have a legal or equitable interest and are not the subject of the LTIP Rules.

The policy also provides that disciplinary action such as counselling, written warning or termination of employment, will be taken where an employee breaches the policy and damage to the Company results.