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Agrimin Limited (ASX:AMN), a minerals exploration and development company, has implemented a revised Securities Trading Policy effective immediately as part of its annual governance review. The updated policy establishes mandatory blackout periods and trading restrictions for directors, senior management, and designated employees to reduce insider trading risks and uphold market integrity. This revision underscores the company's adherence to ASX Listing Rule 12.9 and the Corporations Act 2001 (Cth).
Key Points
- Agrimin Limited (ASX:AMN), a Western Australia-based ASX-listed minerals company, has introduced an updated Securities Trading Policy effective 15 July 2026
- The policy enforces mandatory blackout periods surrounding half-year and full-year results, quarterly reports, and the Annual General Meeting
- Trading restrictions apply to all directors, senior management, employees, designated persons, and their controlled entities and family members
- The Board holds discretion to impose additional trading restrictions without prior notice to prevent insider trading and protect the company’s reputation
Agrimin's Governance Structure and Objectives of the Updated Policy
Agrimin Limited, listed on the Australian Securities Exchange under ticker AMN, has announced the adoption of an updated Securities Trading Policy as part of its annual governance documentation review. Effective from 15 July 2026, the policy is designed to comply with ASX Listing Rule 12.9 and further reinforce the company’s commitment to preventing insider trading while maintaining market confidence. Headquartered at Level 3, 435 Roberts Road, Subiaco, Western Australia, Agrimin operates as a minerals exploration and development company subject to continuous disclosure obligations.
The updated policy aims to minimise insider trading risks under the Corporations Act 2001 (Cth), avoid any appearance of insider trading, and safeguard the company’s reputation from potential damage due to perceived improper trading conduct. While Agrimin Persons are not prohibited from trading company securities, the policy restricts trading during sensitive periods, reflecting best practice corporate governance and aligning with market expectations for ASX-listed companies.
Definition of Agrimin Persons and Extent of Trading Restrictions
The revised policy broadly defines "Agrimin Persons" to include all directors, the Chief Executive Officer, Company Secretary, Key Management Personnel as per the Corporations Act, all employees, and any other individuals designated by the Board in writing. It also extends to companies or trusts controlled by these individuals and, for insider information restrictions, includes spouses (including de facto), children (including step and adopted), and financially dependent persons or those acting in concert with designated individuals.
This comprehensive scope prevents circumvention of trading restrictions through indirect dealings by family members or controlled entities. The policy governs dealings in Agrimin securities and securities of other entities where Agrimin Persons acquire inside information through their role or dealings with the company. This extension acknowledges that insider information may relate to third-party securities and must be protected across all trading activities by restricted persons.
Inside Information Definition and Individual Responsibility
The policy defines Inside Information as non-public information that a reasonable person would expect to materially affect the price or value of Agrimin securities or influence trading decisions. Each Agrimin Person must assess whether they hold Inside Information and determine if it would likely impact a typical investor’s decision to trade.
Trading in Agrimin securities is strictly prohibited for any Agrimin Person possessing Inside Information, regardless of blackout periods, policy exclusions, or exceptional clearances. This absolute prohibition ensures compliance with the law and maintains market integrity.
Mandatory Blackout Periods Surrounding Financial Disclosures and Company Events
The updated policy mandates five blackout periods during which Agrimin Persons cannot trade Agrimin securities. These include the five trading days before and 24 hours after half-year and full-year results releases; five trading days before and 24 hours after quarterly reports; and from two weeks before the Annual General Meeting until 10:00am (Sydney time) on the trading day after the AGM. The Board may also specify additional blackout periods as needed. These restrictions prevent trading on price-sensitive information during critical disclosure periods.
Board’s Authority to Enforce Additional Trading Restrictions
Beyond mandated blackout periods, the Board may impose ad-hoc trading restrictions without notice at its sole discretion, applying to any Agrimin Persons or other staff. This flexibility allows the company to address unforeseen insider trading risks arising from material events outside scheduled reporting cycles. All such restrictions must remain confidential to prevent circumvention.
Insider Trading and Information Disclosure Prohibitions
The policy enforces an absolute ban on insider trading. Agrimin Persons in possession of Inside Information must not trade, procure others to trade, or disclose such information for personal gain. This prohibition extends to securities of external companies when Inside Information is obtained through Agrimin dealings. The policy complements statutory insider trading laws under the Corporations Act, which carry significant penalties for breaches.
Exceptions and Clearance Procedures for Trading
While the policy allows limited exceptions and clearance processes for trading, these do not override the absolute ban on trading when in possession of Inside Information. Detailed procedures are outlined in the full Securities Trading Policy available on Agrimin’s website. The announcement references these provisions without exhaustive detail.
Compliance with ASX Listing Rules and Corporations Act
The updated policy aligns with ASX Listing Rule 12.9 and the Corporations Act 2001 (Cth), clarifying that statutory law prevails over internal policy in case of inconsistencies. This ensures Agrimin’s governance framework supports legal market integrity requirements and communicates the company’s serious stance on insider trading prevention.
By adopting this policy, Agrimin demonstrates to investors, regulators, and the market its commitment to robust insider trading controls and transparent governance, enhancing confidence in the company’s compliance mechanisms.
Contact Information and Policy Access for Investors and Stakeholders
For further details on the updated Securities Trading Policy or related matters, investors and stakeholders may contact Michael Hartley, Executive Director, at +61 8 9389 5363 or [email protected]. Media inquiries can be directed to Michael Vaughan of Fivemark Partners at +61 422 602 720 or [email protected]. The full Securities Trading Policy and corporate governance documents are available at www.agrimin.com.au.
The company update dated 17 July 2026 was authorised by Agrimin’s Board, confirming the policy’s formal adoption. The effective date of 15 July 2026 ensures immediate application of the updated framework for all Agrimin Persons, with no transition period. Stakeholders are encouraged to review the complete policy to fully understand trading restrictions and compliance obligations.
