Revised Securities Trading Policy

NZX Code: ATM
ASX Code: A2M

The a2 Milk Company Limited
www.thea2milkcompany.com


22 August 2019
NZX/ASX Market Release

Revised Securities Trading Policy
In accordance with ASX Listing Rule 12.10, The a2 Milk Company attaches a revised Securities Trading Policy.


Jaron McVicar
General Counsel & Company Secretary
The a2 Milk Company Limited

For further information, please contact:
Investors / Analysts
David Akers
Head of Investor Relations
T +61 2 9697 7013 l M +61 412 944 577
david.akers@a2milk.com

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SECURITIES TRADING POLICY
THE a2 MILK COMPANY LIMITED ("Company")
1. Scope
This Policy sets out the Company's policy on dealing by Directors and employees in:
• securities of the Company (the "Company Securities"); and
• securities of other entities.
If you do not understand any part of this policy, the summary of the law, or how it applies to
you, you should raise the matter with the Company Secretary before dealing with any
securities covered by this policy.
2. Purpose
Under New Zealand and Australian legislation, the insider trading laws operate to prohibit
people in possession of non-public price sensitive information from dealing in securities or
passing on the information to other people who may deal in securities.
Given the restrictions imposed by law, this policy is relevant to all Directors, employees and
contractors of the Company and their associates. This policy also imposes additional
restrictions (described below) on:
• all Directors and officers of the Company including the CEO;
• all employees who occupy a position that allows that employee to exercise significant
influence over the management and administration of the Company, including all direct
reports to the CEO ("Senior Executives");
• their associates (as defined in the Takeovers Code); and
• other persons identified by the Company from time to time
("Restricted Persons").
3. Meaning of Securities
For the purposes of this policy, “Securities” means shares, debentures, options to subscribe for
new shares and options over existing shares, warrant contracts and other derivatives relating
to the shares.

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4. Insider Trading Laws
4.1 Prohibition
If you have any inside information about the Company (or another relevant entity, such as a
company with which the Company is considering a transaction) which is not publicly known, it
is a criminal offence for you to:
• trade in the Company Securities (or securities of the other relevant entity);
• advise or procure another person to trade in the Company Securities (or securities of the
other relevant entity); or
• pass on inside information to someone else (including colleagues, family or friends)
knowing (or where you should have reasonably known) that the other person will, or is
likely to, use that information to trade in, or procure someone else to trade in, the
Company Securities (or securities of the other relevant entity).
4.2 Consequences of insider trading
This offence, called "insider trading", can subject you to:
• criminal liability including large fines and/or imprisonment;
• a civil penalty; and/or
• civil liability, which may include being sued for any loss suffered as a result of illegal
trading.
4.3 Inside information
"Inside information" is information that:
• is not generally available; and
• if it were generally available, would – or would be likely to – influence investors in
deciding whether to buy or sell particular Securities.
The financial impact of the information is important, but strategic and other implications can
be equally important in determining whether information is inside information. The definition
of information is broad enough to include rumours, matters of supposition, intentions of a
person (including the Company) and information which is insufficiently definite to warrant
disclosure to the public. False information can be inside information.
Importantly, you need not be an "insider" to come across inside information. That is, it does
not matter how you come to know the inside information (for example, you could learn it in
the course of carrying out your responsibilities or in passing in the corridor or in a lift or at a
dinner party).
4.4 Insider trading is prohibited at all times
If you possess inside information, you must not buy or sell the Company Securities, advise or
get others to do so or pass on the inside information to others. This prohibition applies
regardless of how you learn the information.

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The prohibition on insider trading applies not only to information concerning the Company
Securities. If a person has inside information in relation to securities of another company, that
person must not deal in those securities.
5. Confidential Information
Related to the above, Directors, employees and contractors also have a duty of confidentiality
to the Company. You must not reveal any confidential information concerning the Company,
use that information in any way which may injure or cause loss to the Company, or use that
confidential information to gain an advantage for yourself.
6. Trading restrictions imposed by this policy
6.1 Additional restrictions
Additional restrictions (described below) on trading the Company Securities apply to Restricted
Persons (as defined above). The additional restrictions in this policy do not prohibit Restricted
Persons from acquiring securities under a Company dividend reinvestment plan or an
employee share plan, if either plan exists (however, the additional restrictions will apply to any
subsequent trading of the Company Securities acquired under those plans).
6.2 Reasons for additional restrictions
Restricted Persons are in positions where it may be assumed that they may come into
possession of inside information and, as a result, any trading by Restricted Persons may
embarrass or reflect badly on them or on the Company (even if a Restricted Person has no
actual inside information at the time). This policy is designed to avoid the possibility that
misconceptions, misunderstandings or suspicions might arise.
6.3 Blackout periods
Restricted Persons must not deal in the Company's Securities during any of the following
blackout periods:
• the period each year from the close of trading one week before the end of the full
financial year until 10.00am on the second trading day following the announcement to
NZX and ASX of the preliminary final statement or full year results;
• the period each year from the close of trading one week before the end of the financial
half year until 10.00am on the second trading day following the announcement of half-
yearly results; and
• any other period that the Company specifies from time to time.
6.4 No speculative short term trading or short selling
Restricted Persons should not trade in the Company Securities on a short term basis or for
speculative trading gain or short sell any Company Securities.
6.5 Exceptional circumstances
If a Restricted Person needs to deal in the Company Securities due to exceptional
circumstances but such dealing would breach rule 6.3 or 6.4 of this Policy, the Restricted

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Person must apply to the person specified in rule 7 for a waiver from compliance with the
provisions in rule 6.3 or 6.4.
Exceptional circumstances include severe financial hardship, compulsion by a court order or
any other circumstances that is deemed exceptional by the person described in rule 7.
The Restricted Person seeking a waiver under this rule must apply in writing to the person
specified in rule 7 setting out the circumstances of the proposed dealing (including an
explanation as to the severe financial hardship or circumstances that are otherwise
exceptional), the reason the waiver is requested and confirmation that the Restricted Person is
not in possession of inside information. A waiver will only be granted if the Restricted Person's
application is accompanied by sufficient evidence (in the opinion of the person specified in rule
7) that the dealing of the relevant securities is the most reasonable course of action available
in the circumstances.
If a waiver is granted, the Restricted Person will be notified in writing (which may include
notification via email) and in each circumstance the duration of the waiver to deal in securities
will be 2 business days.
Unless otherwise specified in the notice, any dealing permitted under this rule must comply
with the other sections of this Policy (to the extent applicable).
6.6 Permitted dealings
Where rules 4.1, 6.3 or 6.4 do not apply, Restricted Persons are permitted to trade the
Company Securities subject to the notification and approval requirements set out below.
Restricted Persons must notify the Company in advance of any proposed dealing in Company
Securities. The notification, which must be made to the person in rule 7, requires the
Restricted Person to confirm that they do not hold any inside information.
The proposed dealing must not be entered into until written clearance has been given by the
person nominated in rule 7. In determining whether to clear the proposed dealing, the
relevant person nominated in rule 7 will consider whether the proposed dealing is appropriate
having regard to all relevant circumstances. Clearance will usually only be considered
appropriate during the following ‘trading windows’:
• the eight-week period commencing on and from 10.00am on the second trading day
following the announcement to NZX and ASX of the Company’s preliminary final
statement or full year results;
• the eight-week period commencing on and from 10.00am on the second trading day
following the announcement of the Company’s half-yearly results;
• the 4 week period commencing on and from 10.00am on the second trading day following
any announcement that ‘cleanses’ the Company of information it had previously not
disclosed to the market in reliance on a safe harbour/exception to the continuous
disclosure rules; and
• any other period approved by the Board from time to time.
Clearance to deal in Company Securities can be revoked at any time but will otherwise be valid
(unless another period is otherwise specified in the clearance) for a period of ten trading days
commencing on the date following the clearance being obtained. If a cleared dealing has not

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been executed within this ten-day period, the Restricted Person will be required to make a
fresh notification under this rule 6.6 prior to entering into the proposed dealing.
6.7 Requirements after trading
Once a Restricted Person has completed a trade in the Company Securities, the relevant
person described in rule 7, must be immediately:
• advised that the trade has been completed; and
• in the case of Directors and Senior Executives, provided with sufficient information to
enable the Company to comply with the requirements to notify a change of interests to
NZX and ASX, and to update its interests register maintained for this purpose.
6.8 Application to employee share and option plans
The additional restrictions in this policy do not affect a Restricted Person's participation in any
Company employee share or option plans or the exercise of options/rights under those plans.
However the additional restrictions in this policy may apply to any subsequent trade of any the
Company Securities issued to (or for the benefit of) a Restricted Person on the exercise of any
options granted under an employee share or option plan.
6.9 No hedging
A Restricted Person must not, without prior written approval by the relevant person specified
in rule 7, engage in hedging arrangements, deal in derivatives or enter into other
arrangements which vary economic risk related to the Company's Securities including, for
example, dealing in warrants, equity swaps, put and call options, contracts for difference and
other contracts intended to secure a profit or avoid a loss based on fluctuations in the price of
the Company's Securities. This provision includes engaging in hedging or other arrangements
that have the effect of limiting the economic risk in connection with unvested securities issued
pursuant to any employee option or share plan.
6.10 Margin or securities lending
Restricted Persons must notify the Company in advance before engaging in any margin or
securities lending arrangements or granting a security interest or other encumbrance over
Company Securities. The notification must be made to the person in rule 7. The proposed
arrangement must not be entered into or grant made until written clearance has been given
by the person nominated in rule 7.

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7. Clearances and Notifications
Where this Policy requires a notification to occur, or clearance, or waiver to be obtained
(unless the context requires otherwise) the table below sets out who the relevant Restricted
Person must notify or seek approval from.
Restricted Person Person to notify and obtain clearance
Chair of the Board The Board
Other Directors (including CEO) Chair of the Board
Senior Executives Chair of the Board and the CEO
Other persons identified by the Company
from time to time
CEO
All Directors are to be notified of any trading in securities by Directors or Senior Executives
8. Breaches of the Policy
Strict compliance with this policy is a condition of employment. Breaches of this policy will be
subject to disciplinary action, which may include termination of employment.
9. Further Information
For more information about this policy, contact the Company Secretary.
Version: 4
Version adoption date: August 2019
Next review date: As required