Refresh Group

This applies to anybody who has access to material non-public information regarding the Company. This would generally include members of the immediate family living in the household of directors and executives. By definition any person who possesses material non-public information regarding the Company is classified as an insider for so long as the information is not publicly known. In principle anyone could become an insider regarding another company should they receive material non-public information from an insider.

It is not possible to define all categories of material information. However it should be regarded as material if it was known there would be a reasonable likelihood that it would be considered important to an investor in making an investment decision regarding the purchase or sale of the Company's shares.

While it is difficult to determine what information is material, there are various categories of information that are particularly sensitive, and as a rule should always be considered material. Examples may include:

Note that either positive or negative information may be material.

No insiders shall disclose material non-public information to any person (including family) who may use such information for personal profit.

If a director or executive possesses material non-public information, they will be precluded from making a Refresh share transaction until one trading day after the time of public release of that information.

Maintaining Confidentiality

The maintenance of confidentiality is essential, both from a legal and practical viewpoint. It impacts on the Company's ability to comply with Corporations Law, ASX Listing Rules and to conduct its business. Accordingly, all material non-public information will be disseminated within the Company on a need-to-know basis.

Information is generally considered material if it would be relevant to an investor making a decision on buying or selling the Company's stock.

All employees must make an effort to maintain the confidentiality of the Company's information. These efforts should include secure handling and storage of confidential documents and avoiding casual conversations regarding confidential matters.

The Chief Executive Officer is the designated Company executive spokesperson. No other employees of the Company are authorised to represent the Company to the media or securities analysts unless expressly authorised to make such disclosure by the Chief Executive Officer.

Summary

These rules are designed to clarify director and employee obligations in relation to trading in Refresh shares, and to help them should they wish to buy or sell Refresh shares.

The insider trading provisions of the Corporations Law are onerous and extremely difficult to defend.

Breaches of the insider trading rules would reflect badly on the Company as a whole.

All queries regarding issues raised in this document should be directed to the Company Secretary.