Range International : Securities Trading Policy

SECURITIES TRADING POLICY

Liability limited by a scheme approved under Professional Standards Legislation.

Range International Limited ACN 611 998 200

Adopted on 31 March 2022

SECURITIES TRADING POLICY

INTRODUCTION AND PURPOSE

Range International Limited (ACN 611 998 200) (Company) and its subsidiaries (Group) is committed to complying with insider trading laws and establishing a best practice procedure for dealing in securities. This document sets out the Company's policy on dealing by Directors and employees in securities of the Company (Company Securities) and securities of other entities.

The purpose of this policy is to:

ensure that all Directors, employees and contractors of the Company (and their associates) are aware of the insider trading laws as they apply to trading in Company Securities; and

protect the reputation of the Company and its Directors and officers by seeking to avoid the possibility that misconceptions, misunderstandings or suspicions might arise as a result of trading by Directors and others who may be, or be perceived to be, in possession of inside information. This policy seeks to do so by imposing additional restrictions on the trading of securities by Restricted Persons (defined below).

WHO DOES THIS POLICY APPLY TO

Unless otherwise stated, this policy applies to:

all Directors of the Group;

all employees of the Group, whether full time, part time or casual; and all contractors and consultants working for the Group,

(each, Personnel).

MEANING OF SECURITIES

For the purposes of this policy, "securities" means shares, debentures, options to subscribe for new shares and options over existing shares, warrant contracts and other derivatives relating to the shares.

INSIDER TRADING LAWS

4.1

Prohibition

In summary, if you have any inside information (defined in section4.2below) about the Company (or another relevant entity, such as a company with which the Company is considering a transaction) which is not publicly known, it is a criminal offence for you to:

trade in Company Securities (or securities of the other relevant entity);

advise or procure another person to trade in Company Securities (or securities of the other relevant entity); 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, or is likely to, use that information to trade in, or procure someone else to trade in, Company Securities (or securities of the other relevant entity).

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 of the Company for any loss suffered as a result of illegal trading.

• 4.2 Inside information

  "Inside information" is information that:

  is not generally available; and

  if it were generally available, a reasonable person would expect that it would - or would be likely to - influence investors in deciding whether to buy or sell particular securities.

  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 the Company) and information which is insufficiently definite to warrant disclosure to the public.

  Importantly, you need not be an "insider" to come across inside information. That is, it does not matter how you come to know the inside information (for example, you could 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).

• 4.3 Examples of insider trading

  The following list is illustrative only. Inside information could include:

the financial performance of the Company against its budget; a possible acquisition or sale of any assets by the Company; a possible change in the Company's capital structure;

market sensitive information such as a material upgrade or downgrade in forecast earnings; a material trading update;

a proposed dividend;

senior management changes;

development of a new business line or product offering; or

any possible claim against the Company or other unexpected liability.

• 4.4 Insider trading is prohibited at all times

  If you possess inside information, you must not buy or sell Company Securities, advise or get others to do so or pass on the inside information to others. This prohibition applies regardless of how you learn the information.

  The prohibition on insider trading applies not only to information concerning Company Securities. If a person has inside information in relation to securities of another company, that person must not deal in those securities.

  CONFIDENTIAL INFORMATION

  Related to the above, Directors, employees and contractors also have a duty of confidentiality to the Company. You must not reveal any confidential information concerning the Company, use that information in any way which may injure or cause loss to the Company, or use that confidential information to gain an advantage for yourself.

  TRADING RESTRICTIONS IMPOSED BY THIS POLICY

• 6.1 Additional restrictions

  Additional restrictions (described below) on trading Company Securities apply to Restricted Persons (described below).

• 6.2 Restricted Persons

  For the purpose of this policy, Restricted Persons are:

  all Directors including the CEO;

  all other key management personnel of the Company; and

  employees who have been notified that they are Restricted Persons for the purpose of this policy.

• 6.3 Close family members and entities closely connected with Restricted Persons

  For this policy:

a close family member of a Restricted Person means a spouse or de facto, any minor children or children living with the Restricted Person (including children of the Restricted Person's spouse or de facto); and

a closely connected entity of a Restriction Person means any family company or family trust that the Restricted Person or their close family members may control or have an interest in,

(together Closely Connected Persons).

Each Restricted Person must:

ensure that any trading by their Closely Connected Persons are undertaken in accordance with this policy; and

ensure that his or her Closely Connected Persons are aware of this policy and the restrictions it contains.

• 6.4 Reasons for additional restrictions

  Restricted Persons are in positions where it may be assumed that they may come into possession of inside information and, as a result, any trading by Restricted Persons (or their Closely Connected Persons) may embarrass or reflect badly on them or on the Company (even if a Restricted Person has no actual inside information at the time).

  This policy is designed to avoid the possibility that misconceptions, misunderstandings or suspicions might arise and also to protect the reputation of the Company and Restricted Persons.

• 6.5 Restrictions on dealing

  Restricted Persons must not deal in Company Securities:

  without prior approval (see section Error! Reference source not found.); and during any of the following blackout periods:

  the period each year from the close of trading at the end of the full financial year until 10.00am on the next trading day following the date of announcement to ASX of the preliminary final statement or full year results;

  the period each year from the close of trading at the end of the full financial year until 10.00am on the next trading day following the date of announcement of half-yearly results; the period each year from the close of trading at the end of each quarter end until 10.00am on the next trading day following the date of announcement of quarterly results;

  within 24 hours after the release of market sensitive information under ASX Listing Rule 3.1; and

  any other period that the Company specifies from time to time,

  (each a Blackout Period).

• 6.6 No speculative short-term trading

  Restricted Persons should not trade in Company Securities on a short-term basis or for speculative trading gain. The Company considers "short-term" to be a period of 6 months or less.

• 6.7 Short-selling, hedging and margin lending transactions

A Restricted Person must not engage in short-selling in respect of Company Securities.

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