Philosophy
Neon requires all employees and Directors to inform the Managing Director or in his absence, the Company Secretary, of any potentially price sensitive material or information as soon as practicable after they become aware of that information.
The Company will promptly disclose such information to the market, subject to the following procedures and guidelines.

Procedures and Guidelines
Information is material if it is likely that the information would influence investors who commonly acquire securities on ASX in deciding whether to by, sell or hold the Company’s securities. Neon complies in full with the requirements of ASX Listing Rule 3.1 in the implementation of this policy.

The Managing Director is responsible for interpreting and monitoring the Company’s disclosure policy and where necessary informing the Board. The Company Secretary is responsible for all communications with ASX.  Prior to any media or ASX release being made, two Directors, one of which must be the Managing Director or Finance Director, must first approve the release by email or telephone.

Communication with Shareholders:
The Board of Neon places considerable importance on effective communications with shareholders.
The Company’s communication strategy requires communication with shareholders and other stakeholders in an open, regular and timely manner so that the market has sufficient information to make informed investment decisions on the operations and results of Neon.

The strategy provides for the use of systems that ensure a regular and timely release of information about the Company is provided to shareholders. Mechanisms employed include:

• Media and ASX announcements;
• Maintenance of an informative website;
• Regular presentations to major shareholders and potential investors;
• Directors answering queries from shareholders in a timely manner via email or telephone;
• Regular statutory reporting, both to ASX and shareholders; and
• Presentations by Managing Director at the Annual General Meeting and General Meeting’s.

The Board encourages full participation of shareholders at the Annual General Meeting to ensure a high level of accountability and understanding of Neon’s strategy and goals.
The Company also posts all reports, ASX and media releases and copies of significant business presentations on the Company’s website.

Compliance with ASX Corporate Governance Recommendations

The Company currently complies with the ASX Principles and Recommendations other than in relation to the matters specified below.

Dealings in Company Securities

Philosophy
The Board encourages its employees to invest in Neon but places restrictions on buying and selling shares in the Company if that employee may be in possession of Price Sensitive Information. Directors and employees are restricted from trading shares in the Company and Directors are discouraged from buying or selling shares without first consulting and seeking approval from the Chairman.
Price Sensitive Information is information that:
is not generally available; and
if it were generally available, it would, or would be likely to influence investors in deciding whether to buy Neon’s shares.

Procedures and Guidelines
If any Director or employee possesses Price Sensitive Information, the person must not:

• trade in Neon securities;
• advise others or procure others to trade in Neon securities; or
• pass on the inside information to others including colleagues, family or friends – knowing (or where the employee or Director should have reasonable known) that the other persons will use that information to trade in, or procure someone else to trade in Neon securities.

This prohibition applies regardless of how the employee or Director learns the information.
Directors and employees are restricted from buying or selling Neon shares, or shares in any of the Company’s partners, irrespective whether they are listed or not, during price sensitive activities, which include but are not limited to:

• During the drilling or testing of a well that may have a material impact on the price of Neon shares. The restriction applies from 48 hours prior to the anticipated intersection of a potentially productive reservoir, or 48 hours prior to the testing of a potentially productive zone, and will continue to apply until 48 hours after an announcement on the drilling or test results have been made publicly available.
• Two weeks prior to the release of any financial data, including annual, half yearly and quarterly reports and applies for 48 hours after the release of the relevant report. The same restriction applies following an announcement of a material event relating to the Company’s business and operations.

Employees should check with the Company Secretary before buying any of the Company’s securities and Directors are encouraged to consult with the Chairman prior to buying or selling any securities in the Company.

In addition to the above, Directors must notify the Company Secretary as soon as practicable, but not later than 5 business days after they have bought or sold the Company’s securities or exercised options. In accordance with the provisions of the Corporations Act and the Listing rules of ASX, the Company on behalf of the Directors must advise ASX of any transactions conducted by them in the securities of the Company.

Breaches of this policy will be subject to disciplinary action, which may include termination of employment.