DEALING IN SECURITIES

In accordance with the Listings Requirements of the JSE, the Company has adopted a Trading in Securities policy. In terms of the policy, there is a "closed period" that endures from the end of the financial reporting period until the publication of financial results for this period. Additional closed periods may be declared from time to time if circumstances so warrant.

During closed periods, directors and designated employees are prohibited from dealing in the Company's securities, either directly or indirectly, on the basis of unpublished price sensitive information about the business of the Group. Identified employees are advised to that effect.

The Company secretary advises the directors of all the closed periods.

Dealings in securities by directors and officers of the Company require prior approval by the chairman or the chief executive, depending on the person dealing in the securities. Any share dealings by directors and officers of the Company are notified to the JSE for publication via the Securities Exchange News Service (SENS).

The Company also has in place an information disclosure and communications policy designed to:

• record AECI's procedure with regard to communicating with the media, investment community, securities professionals and other audiences to avoid selective disclosure of material information; and
• govern the disclosure of price sensitive information to the public in a broad, comprehensive and lawful manner.

This policy has been brought to the attention of all AECI employees and must be adhered to by them.