Classification: External

Trading in ANZ Securities Policy
Policy Owner: Head OR&C, Institutional Risk
Policy Level: Group

Version 1.2
1 June 2024

This policy provides a globally consistent approach to Trading in ANZ Securities and seeks to ensure ANZ
requirements and all relevant legal obligations are met.
This policy puts in place systems and processes aimed at preventing insider trading or trading that could
be perceived as insider trading, to:a. support the delivery of fair outcomes for our customers and the community and protect
market integrity,
b. support ANZ’s Code of Conduct which sets the standards for the way we do business at ANZ
and to successfully navigate ethical challenges that may be encountered in our work,c.

avoid significant potential damage to ANZ’s reputation that any such trading may cause,d. along with the Conduct Risk Framework and the Non-Financial Risk Framework, support theeffective identification, action and monitoring of conduct risk.
Capitalised terms used throughout this policy have the meanings given in the Glossary.
APPLICATIONThis policy applies to all ANZ Directors and all Employees and Contingent Workers of the ANZ Bank
Group. To understand how this policy applies you will need to check whether you are a Restricted Person.
POLICY DETAILOBLIGATIONS UNDER THIS POLICY
Background
This section sets out:•

the obligations applicable to all individuals to whom this policy applies;•

the additional obligations applicable to Restricted Persons other than ANZ Directors;•

the additional obligations applicable to all Restricted Persons; and•the additional obligations applicable to ANZ Directors, ExCo members, direct reports to the ANZ CEO
and the ANZGHL Company Secretary.

Obligations applicable to all individuals
1. Insider trading is illegal: Individuals will act with honesty and integrity and not Trade, oradvise, procure, or encourage another person to Trade in ANZ Securities at any time when inpossession of Inside Information. For avoidance of doubt, this applies even if:
a. the Trade would occur outside a Blackout Period;b. the Trade is covered by an exception under section 10 of this policy where Trading ispermitted without Pre-Trade Approval;c.

a Pre-Trade Approval or Special Circumstances Trading Application has been granted; or

d. this policy otherwise provides a clearance or approval to Trade.
Note: Printed versions of this document may be obsolete. Please check MAX for the latest version.

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TRADING IN ANZ SECURITIES POLICY
Inside Information must not be disclosed or passed on to any other person by any individual otherthan in connection with the proper carrying out of the individual’s role and duties at ANZ.
2. Hedging interests is prohibited: Individuals will not and must ensure that others do not on
their behalf, hedge any interests that have been granted to the individual under any ANZ
employee equity plan that are either unvested or subject to a holding lock.
Obligations applicable to Restricted Persons other than ANZ Directors
3. Actions required to use ANZ’s Personal Account Dealing Platform: Each Restricted Person
other than ANZ Directors must take the actions as described in the following table:
Circumstances where action
is required:
•
•

•

•

What the Restricted
Person must do:

By when:Restricted Person has anactive Brokerage Account.
Restricted Person’s Associated
Person has an active
Brokerage Account.

Disclose and register each
Brokerage Account of the
Restricted Person and their
Associated Persons in the
Personal Account Dealing
Platform

Before submitting first PreTrade Approval request.

Restricted Person’s
Brokerage Account is not
integrated with the Personal
Account Dealing Platform.
Restricted Person’s Associated
Person has a Brokerage
Account which is not
integrated with the Personal
Account Dealing Platform.

Manually submit Broker
Statements for eachregistered Brokerage Accountinto the Personal Account
Dealing Platform. BrokerageStatements for integrated
Brokerage Accounts are notrequired to be uploaded.

You may be asked by theCompliance Control Room tosubmit monthly where requiredin your location, but otherwise
promptly when requested by theCompliance Control Room.

Obligations applicable to all Restricted Persons
4. Inform Associated Persons of obligations: Restricted Persons should inform their Associated
Persons that the Restricted Person is prohibited from insider trading and, so that ANZ can monitor
compliance with this requirement and this policy:a. the Restricted Person must maintain and disclose to ANZ, Trading records relating to ANZSecurities, including those of the Associated Person; andb. ANZ requires Pre-Trade Approval of Trading in ANZ Securities by both the Restricted Person
and their Associated Persons.
5. Maintain records: Restricted Persons will maintain and will seek to ensure that their Associated
Persons maintain, records of all Trading in ANZ Securities (including where applicable any related
Pre-Trade Approvals or approved Special Circumstances Trading Applications) for 12 months.
6. Inspection of records: On request by Compliance, the Compliance Control Room or Internal
Audit, Restricted Persons will provide for inspection, their ANZ Securities Trading records and the
ANZ Securities Trading records of their Associated Persons to confirm adherence to this policy.
7. No Trading during Blackout Period: Restricted Persons will not and must seek to ensure their
Associated Persons do not, Trade in ANZ Securities during a Blackout Period, unless one of the
exceptions permitting trading during a Blackout Period in section 10 applies, or a Special
Circumstances Trading Application has been approved and is expressed to permit Trading during
the Blackout Period.

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TRADING IN ANZ SECURITIES POLICY
8. No speculative trading: Restricted Persons will not and must seek to ensure their Associated
Persons do not, engage in speculative Trading of ANZ Securities. Without limiting the forgoing,
this means:a. Restricted Persons will not, and must seek to ensure that their Associated Persons do not,short-sell ANZ Securities; orb. Restricted Persons will comply and must seek to ensure that their Associated Persons comply,
with the requirement that they hold ANZ Securities purchased or do not buy-back ANZSecurities sold until a minimum period of 30 calendar days has passed since such purchase or
sale. This requirement does not apply to a cashless exercise of ANZ deferred share rights or
performance rights, or where a Special Circumstances Trading Application has been granted.
9. No margin lending: Restricted Persons will not use ANZ Securities in connection with a marginloan or similar financing arrangements that may be subject to a margin call or loan-to-value ratio
breach.
10. Requirement to obtain Pre-Trade Approval: Restricted Persons will obtain Pre-Trade Approvalusing the process described in section 14 before they or their Associated Persons Trade in ANZSecurities, except in the following circumstances:
Rights offers/share buy-backs
a. a disposal of ANZ Securities arising from the acceptance of an equal access share buy-back,takeover offer or scheme of arrangement;b. a disposal of rights acquired under a pro rata issue;c.

an acquisition of ANZ Securities pursuant to a pro rata issue;

d. to undertake or elect to take up entitlements in a rights issue or other offer that has beenannounced on a securities exchange provided the Restricted Person is not in possession of
Inside Information, or to allow such entitlements to lapse;
e. to comply with a compulsory acquisition under the Corporations Act in Australia or underequivalent laws in other jurisdictions;
Acquisition of shares without paymentf.

the receipt of ANZ Securities under ANZ’s yearly Performance Review Process annual incentive
scheme;g. the receipt of ANZ Securities given as a gift without a requirement for any payment (e.g. ANZSecurities left to you in another person’s will);
Dividend Reinvestment Plan (DRP)h. an election to commence, cease or vary participation in ANZ’s dividend reinvestment plan orbonus option plan where such election is made outside a Blackout Period, provided that suchelection is not made at a time when the Restricted Person is in possession of Inside
Information;

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TRADING IN ANZ SECURITIES POLICY
Off Market Transfers/Exercising Optionsi.

a transfer of ANZ Securities to another holding in the Restricted Person’s or Associated
Person’s sole name or to an account in the Restricted Person’s or Associated Person’s solename within a superannuation fund;j.

completed outside a Blackout Period:(i)a transfer of ANZ Securities to a trading account in the name of a Close Family Member
or a company, trust or other entity wholly owned by the Restricted Person, theAssociated Person and/or their Close Family Member;(ii)

an exercise of ANZ deferred share rights or performance rights by the Restricted
Person (i.e. to “acquire and hold” the ANZ Securities that are the subject of thedeferred share right). For the avoidance of doubt, Pre-Trade Approval is required:I.

before disposing of the ANZ Securities acquired following such exercise; andII.

via a Special Circumstances Trading Application, to exercise ANZ deferred sharerights or performance rights during a Blackout Period;k. any mandatory conversion of ANZ Securities (e.g., convertible notes) into ordinary shares,
provided that the conversion is triggered automatically under the terms and conditions
applicable to the ANZ Security without the Restricted Person or their Associated Person’s
active participation or instruction;
Leave taken by Restricted Persons other than ANZ Directorsl.

Restricted Persons other than ANZ Directors are exempt from the Pre-Trade Approvalrequirement while they continue to meet the following conditions:
(i)
(ii)

the Restricted Person has been on leave for a period of greater than 30 calendar days;
andthe Restricted Person was not in possession of any Inside Information at thecommencement of their leave period;

Other exemptions
m. with respect to Associated Persons, if they are Trading within the scope of their own
employment with a third party (e.g. an Associated Person who is a stockbroker Trading in theirprofessional capacity for a non-related party is covered by this exemption; a day trader would
not be covered);n. any indirect and incidental trading of ANZ Securities that occurs as a consequence of a dealing
in securities issued by a managed investment scheme, listed investment company, exchange
traded fund or similar investment vehicle, that is managed by a third party and that happens
to hold ANZ Securities as part of its portfolio; or
o. any additional exceptions determined by the Policy Owner, where applicable.
Obligation applicable to ANZ Directors
11.

ANZ Directors of ANZGHL and its subsidiaries will provide details of all their dealings in ANZSecurities to ANZ’s Corporate Governance team including any related information required
under applicable listing rules to enable compliance with applicable disclosure obligations
regarding Trading by ANZ Directors. ANZ Directors of Controlled Entities (other than ANZGHL
subsidiaries) will provide details of all their dealings in ANZ Securities to ANZ’s ComplianceControl Room.

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TRADING IN ANZ SECURITIES POLICY
Obligations applicable to ExCo members, ANZGHL Company Secretary and certain others
notified
12. DRP Pricing: ExCo members, the ANZGHL Company Secretary and any other individuals
determined to be (and notified as being) subject to this requirement by the ANZ CEO, Chief Risk
Officer and Group General Counsel from time to time will not and must seek to ensure their
Associated Persons do not, trade in ANZ Securities during a DRP Pricing Period.
13. Shareholding Guidelines: ExCo members must ensure that any requests for Pre-Trade Approvalmeet the requirements of the Shareholding Guidelines (i.e., Requests for Pre-Trade Approvalshould not take the ExCo member’s eligible holdings below the minimum holding requirement).
How to obtain a Pre-Trade Approval and related provisions
14. A request for Pre-Trade Approval will be made by a Restricted Person and the decision to approve
the request will be made as described in the following table:
Restricted Person:

How to apply:

Decision madeby:

ANZ Directors of
ANZGHL and
ANZBGL, including
the ANZ CEO

In writing (cc’d to the ANZGHL Company Secretary) to
the Chairman of the ANZGHL Board or, if the Chairmanof the ANZGHL Board is not available, the Chairman of
the ANZGHL Audit Committee (or in the case of the
Chairman of the ANZGHL Board, from the Chairman of
the ANZGHL Audit Committee).

The Chairman of
the ANZGHLBoard orChairman of the
ANZGHL Audit
Committee, asapplicable

All other Restricted
Persons (including allother ANZ Directors
excluding ANZ
Directors of ANZGHL
and ANZBGL)

Apply using the Personal Account Dealing Platform *unless the Compliance Control Room directs that analternative platform or process be used.

ComplianceControl Room*For ANZ Directors of ANZGHL subsidiaries (excluding
ANZBGL), apply via corpgovemelb@anz.com. The
Company Secretary will seek written Pre-Trade
Approval on your behalf and advise the outcome toyou.
* For ANZ Directors of a Controlled Entity that is not an
ANZGHL subsidiary, apply via
anzcontrolroom@anz.com

15. A request for any Pre-Trade Approval can be approved or declined by ANZ at its sole discretion,
without giving any reasons, and can be withdrawn at any time if new information becomes knownor there is a change in circumstances. ANZ’s decision to decline a Pre-Trade Approval request is
final and binding. Where a request is declined, the outcome is considered confidential informationand must not be disclosed.
16. Any Pre-Trade Approval granted is not an endorsement of the proposed Trade. The person doing
the Trading is individually responsible for their investment decisions and compliance with insider
trading laws. Before Trading, individuals should consider carefully whether they are in possessionof any Inside Information, and if in any doubt, they should not Trade. If an individual comes intopossession of Inside Information after receiving Pre-Trade Approval, the individual must not Tradedespite having received the Pre-Trade Approval.

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TRADING IN ANZ SECURITIES POLICY
17. A Pre-Trade Approval is valid only during the Effective Period. If the order is not executed within
the Effective Period, the Restricted Person must submit a new Pre-Trade Approval request toensure a valid Pre-Trade Approval has been obtained when the order is executed. This also
applies to limit orders.
SPECIAL CIRCUMSTANCES TRADING APPLICATIONS
Background
This section sets out the special circumstances in which disposal of ANZ Securities by Restricted Persons(or their Associated Persons) that was previously declined or is otherwise prohibited by this policy may bepermitted with prior written approval.
Policy Statements
18. A Special Circumstances Trading Application may be sought where a need arises to dispose ANZ
Securities:
a. during a Blackout Period;b. during the 30-day minimum holding period described in section 8b; orc.

where a Pre-Trade Approval request has been declined,

as a result of severe financial hardship, a pressing financial commitment that cannot be satisfied
otherwise than by disposing of ANZ Securities, or in other exceptional circumstances.
19. A Special Circumstances Trading Application should be made by a Restricted Person and thedecision to approve the request will be made as described in the following table:
Restricted Person:

How to apply:

Decision made by:

ANZ Directors of
ANZGHL and ANZBGL,
including the ANZCEO

In writing (cc’d to the ANZGHL Company
Secretary) to the Chairman of the ANZGHLBoard or, if the Chairman of the ANZGHL Board
is not available, the Chairman of the ANZGHL
Audit Committee (or in the case of the Chairmanof the ANZGHL Board, from the Chairman of the
ANZGHL Audit Committee).

The Chairman of the
ANZGHL Board or
Chairman of the ANZGHL
Audit Committee, asapplicable

All other Restricted
Persons (including allother ANZ Directors
excluding ANZ
Directors of ANZGHL
and ANZBGL)

Apply using the Personal Account Dealing
Platform * unless the Compliance Control Roomdirects that an alternative platform or process beused.

Line Manager andCompliance Control
Room*For ANZ Directors of ANZGHL subsidiaries(excluding ANZBGL), apply via
corpgovemelb@anz.com. The Company
Secretary will seek written Pre-Trade Approval
on your behalf and advise the outcome to you.
* For ANZ Directors of a Controlled Entity that is
not an ANZGHL subsidiary, apply via
anzcontrolroom@anz.com

20. In considering a Special Circumstances Trading Application, ANZ will have regard to:a. whether the disposal would be likely to affect ANZ’s interest or reputation;b. whether there is any actual or perceived Conflict of Interest;

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TRADING IN ANZ SECURITIES POLICYc.

whether the Restricted Person is in possession of Inside Information; andd. all other relevant factors, including the nature of the exceptional circumstances outlined in theapplicant’s request.
21. In the case of a Special Circumstances Trading Application by an Employee or Contingent Worker
other than the ANZ CEO, the line manager of the applicant will be asked through the Personal
Account Dealing Platform to endorse the application and confirm that they are not aware of any
actual or perceived Conflict of Interest in connection with the application.
22. A decision with respect to a Special Circumstances Trading Application will generally be provided
in writing within 4 Business Days of receipt of the request. Approvals will not be granted
retrospectively, and if an application is declined, that decision is final and binding on the person
submitting the application. ANZ reserves the right not to give a reason for declining theapplication.
23. Where a Special Circumstances Trading Application is approved, the approval will be valid only for
Trading during the Effective Period.

ROLES AND RESPONSIBILITIESROLES AND RESPONSIBILITIES OF ANZ DIRECTORSAll ANZ Directors should be aware of their obligations arising from this policy and abide by theseobligations, and for ANZ Directors of ANZGHL and ANZBGL in conjunction with their obligations under the
ANZ Non-Executive Directors Code of Conduct.
ROLES AND RESPONSIBILITIES OF ALL EMPLOYEES AND CONTINGENT WORKERSAll Employees and Contingent Workers should be aware of their obligations arising from this policy andabide by those obligations in conjunction with their obligations under the ANZ Code of Conduct. In
addition, all Employees and Contingent Workers must comply with their obligations under the ANZ Codeof Conduct to declare upon commencement of employment and acknowledge annually that they
understand the principles of the ANZ Code of Conduct (including in relation to this policy), have compliedwith them in the previous 12 months, and agree to comply with them going forward.
All Employees and Contingent Workers who are Restricted Persons must:•obtain and review a copy of the Privacy Statement; and•provide a copy of the Privacy Statement to their Associated Persons for their review.

Employees and Contingent Workers who are Restricted Persons are required to provide certain
certifications to this effect and agree to the matters set out in the Privacy Statement on their own behalf
and on behalf of their Associated Persons when they first use the Personal Account Dealing Platform andprior to making a Pre-Trade Approval request through the Personal Account Dealing Platform.
ROLES AND RESPONSIBILITIES OF LINE MANAGERS
Line managers of Employees and Contingent Workers will be required to review any Special
Circumstances Trading Applications from their direct reports to trade in ANZ Securities. Line managers
should review and assess whether there is an actual or perceived Conflict of Interest should the Restricted
Person transact in ANZ Securities, considering all relevant facts and circumstances. Line managers should
not endorse a Special Circumstances Trading Application which would lead to a Conflict of Interest withthe requesting Employee’s or Contingent Worker’s role at ANZ. A line manager may consider endorsing
the Special Circumstances Trading Application request if no Conflict of Interest exists. In the case that the7Classification: External

TRADING IN ANZ SECURITIES POLICYLine Manager is absent (or otherwise unable to fulfil their duties), the above listed responsibilities aretransferred to the Individuals Skip Line Manager in accordance with the ANZ Peoplesoft hierarchy.
ROLES AND RESPONSIBILITIES OF THE CORPORATE GOVERNANCE TEAMThe Corporate Governance team is responsible for record keeping in relation to Pre-Trade Approval
applications and decisions in respect of ANZ Directors of ANZGHL and its subsidiaries.
ROLES AND RESPONSIBILITIES OF COMPLIANCE CONTROL ROOMThe Compliance Control Room is responsible for:•Identification and allocation of Employees and Continent Workers known as “Restricted Persons”;•

Record keeping of all Pre-Trade Approval applications and outcomes decisions other than with respect
to ANZ Directors;•

Pre-Trade Approval enforcement and monitoring, including:oactively monitoring Trading in ANZ Securities by ExCo members to meet GN27 obligations;andoactively monitoring Restricted Persons for compliance with this policy, any specific business
unit requirements and any specific country requirements;•

Ensuring that the current version of this policy is available on the ANZ intranet;•

Circulating reminders in relation to Blackout Periods (including by email and on the ANZ intranet);•making reasonable enquiries (both internally and externally) for information to assist in deciding
whether to approve or reject Pre-Trade Approval requests; andRecord keeping for Pre-Trade Approval applications and decisions in respect of ANZ Directors ofControlled Entities other than ANZGHL subsidiaries.

•

POLICY BREACHESAll policy breaches must be immediately escalated to the Policy Owner and will be dealt with inaccordance with the ANZ Global Performance Improvement and Unacceptable Behaviour Policy.
Breaches of this policy will be investigated and will result in an appropriate consequence being applied.
For Employees and Contingent Workers, this may include re-assessment of bonus qualification,prohibition from Trading and/or termination of employment or engagement.
A breach of this policy may also be a contravention of relevant insider trading or other laws, which may
result in financial penalties and/or imprisonment for individuals.
POLICY EXEMPTIONS
All policy exemptions, including country level exemptions to a global policy, must be submitted forapproval to the Policy Owner using the Policy Exemption Form with a copy to Policy Governance.
Country level policies should only be developed where there are specific legal or regulatory requirements
to do so.
LEGAL OBLIGATIONSANZ will comply with the minimum standards set out in this policy. In the event a legal obligation imposesa higher standard or requirement on ANZ, the legal obligation will prevail over the applicable minimum
standard.

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TRADING IN ANZ SECURITIES POLICY
Where local law in any jurisdiction places obligations or procedural requirements on Employees orContingent Workers, which are in addition to the requirements in this policy, Employees and Contingent
Workers must also comply with those obligations or requirements.
If, in performing duties under this policy, an Employee or Contingent Worker complies with a legal
obligation that is inconsistent with this policy, the Employee or Contingent Worker must report thisinconsistency to their local compliance manager and to the Policy Owner.
WHERE TO GET HELP
If you are an ANZ Director of ANZGHL or ANZBGL, contact the Chairman of the ANZGHL Board or ANZ’s
Corporate Governance team.
If you are an ANZ Director of any other ANZGHL subsidiary, contact ANZ’s Corporate Governance team.
In all other cases, contact your line manager, the Compliance Control Room or the Policy Owner.

9Classification: External

TRADING IN ANZ SECURITIES POLICYGLOSSARY
The Policy Glossary contains standard terms For the purposes of this document:
ANZ Bank Groupmeans ANZGHL or a Controlled Entity (as appropriate)

ANZ Director

A person appointed to the Board of Directors of ANZGHL or a Controlled Entity, who
is not an employee or contingent worker.

ANZGHLANZ Group Holdings Limited

ANZ CEO

means the Chief Executive Officer of ANZ.

ANZ Security

means:• a share or bond issued by, or a debenture of ANZGHL or a Controlled Entity;

Associated Person

Blackout Period•

any other security or financial product issued by ANZGHL or a Controlled Entitythat can be Traded on a financial market; or•an option, derivative, future or warrant relating to any security or financial
product referred to above.

means:•

a Close Family Member of the person; or•a company, trust, or other entity the person or the person’s Close Family
Member controls or significantly influences.

means each period:•(quarter trading updates) from the date which is 14 calendar days before thescheduled date for an ANZGHL first quarter trading update or ANZGHL third
quarter trading update as the case may be, through to midday (AEST) on theBusiness Day following the announcement of such trading update;•(half year/interim results) from the later of the end of the 6th Business Day after
the ANZGHL first quarter trading update or the end of the last day in February,
through to midday (AEST) on the Business Day following the announcement of
ANZGHL’s half year/interim results;•(full year/annual results) from the later of the end of the 6th Business Day after
the ANZGHL third quarter trading update or the end of the last day of August,through to midday (AEST) on the Business Day following the announcement of
ANZGHL’s full year/annual results; and•(other) any additional periods determined by ANZ from time to time.

Broker Statement

A statement or record issued by a broker showing securities holdings andtransaction information with respect to a Brokerage Account.

Brokerage AccountAn account maintained by a Restricted Person (other than an ANZ Director) or their
Associated Persons with a broker for holding and transacting in securities.

Business Day

A day that is not a Saturday, a Sunday or a public holiday or bank holiday in theplace concerned.

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TRADING IN ANZ SECURITIES POLICY
Close Family
Memberof a person means:•a spouse/partner (including de facto or same sex partner) of the person; or•a child (who is under 18 years of age) or dependent of the person or of theperson’s spouse/partner (including de facto or same sex partner); or•

anyone else who is one of the person’s family and may be expected to influence
the person, or be influenced by the person, in the person’s dealings with ANZ or
ANZ Securities.

Conflict of Interest

An actual, potential or perceived conflict of interest arises where the specific duties
or interests of a person or entity in respect of an outcome, are not aligned with that
person or entity’s obligations or duties to others to achieve a different outcome.

DRP Pricing Periodmeans in relation to any eligible dividend, the period of 10 trading days (or suchother number of trading days as the Board may determine from time to time)commencing on the third trading day immediately following the record date inrelation to that eligible dividend (or such other day as the Board may determine).

Effective Periodmeans:•

in the case of ANZ Directors of ANZGHL and ANZBGL, such period of time as isdetermined by the Chairman of the ANZGHL Board or the Chairman of the
ANZGHL Audit Committee, as applicable; and•in all other cases, the period of time starting when a Pre-Trade Approval isreceived by the Restricted Person and ending at the earlier of the close of
trading on the second trading day following the day of receipt of the Pre-Trade
Approval, or the start of the first day of the next Blackout Period.

For this purpose, trading day means a day for which the security is eligible to betransacted.
ExComeans the Executive Committee of ANZ.

Inside Information

Information that could be reasonably expected to have a material or significant
effect on the price or value of an ANZ Security and which is not generally available.

Pre-Trade Approval

The submission of a Trade Request for Personal Account Dealing purposes andreceipt of approval from the Compliance Control Room prior to any trading orplacement of an order or execution of any order.

Privacy Statement

The ANZ Personal Account Dealing and Personal Conflicts Privacy Statement whichis available on the ANZ intranet.

Restricted Person

Each of the following are Restricted Persons:•

ANZ Directors; and•any other individuals determined by Compliance & Business Unit management
collectively as a Restricted Person (as stipulated in the Schedule maintained byCompliance) who, because of their seniority or the nature of their position, arelikely to come into contact with key financial, operational, strategic or other11Classification: External

TRADING IN ANZ SECURITIES POLICY
information about ANZ which, should it become generally available, could bereasonably expected to have a material or significant effect on the price orvalue of an ANZ Security.
Refer to the Restricted Person Look-up Tool.
SpecialCircumstances
Trading Application

An application by a Restricted Person to Trade in circumstances that would
otherwise be prohibited under this policy.

Personal Account
Dealing Platform

The online platform provided to ANZ by StarCompliance, Inc., used by ANZ toassist in conducting automated Pre-Trade Approvals. StarCompliance can beaccessed by Employees and Contingent Workers on their mobile device through an
App provided by StarCompliance, Inc. or on their desktop through the ANZ
intranet.

Trade/Tradingof ANZ Securities means:• buying, selling or applying for ANZ Securities or providing an instruction to athird party to do so;•entering into a contract to buy, sell or apply for ANZ Securities, or procuring athird party to do so;•entering into a contract for difference relating to ANZ Securities;•

entering into a contract to buy, sell or exercise a deferred share right or
performance right relating to ANZ Securities;•

the conversion of convertible ANZ Securities;•

exercising ANZ employee deferred share rights or performance rights;•

to elect to commence, cease or vary participation in ANZ’s dividend
reinvestment plan or bonus option plan; or•

spread betting in relation to an ANZ Security.

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