Vita : VTG - Share Trading Policy

Vita Group Limited ACN 113 178 519 77 Hudson Road Albion QLD 4010

26 April 2022

Market Announcements Office Australian Securities Exchange 4th Floor, 20 Bridge Street SYDNEY NSW 2000

ELECTRONIC LODGEMENT

Dear Sir or Madam

Vita Group Limited - Share Trading Policy

In accordance with the Listing Rules, please find attached for immediate release an announcement by Vita Group Limited (ASX: VTG).

Authorised for lodgement by Vita Group's Board of Directors.

Yours sincerely

George Southgate

Chief Legal & Risk Officer | Group Company Secretary Vita Group Limited

ASX ANNOUNCEMENT

Tuesday, 26 April 2022

Revised Share Trading Policy

In accordance with ASX Listing Rule 12.10, Vita Group Limited (ASX: VTG) (Vita) advises that the Vita Board of Directors has approved amendments to Vita's Share Trading Policy with effect from today.

A copy of the revised Share Trading Policy is attached to this announcement.

The revised policy is also available from Vita's website at:https://vitagroup.com.au/shareholders/corporate-governance/.

This announcement has been authorised for lodgement by the Vita Board of Directors.

Further enquiries:

Updated 26 April 2022

Vita Group Limited

ABN 62113 178 519

1.

Introduction

• 1.1 The Corporations Act prohibits the trading in shares, options and other financial products of a company by any person who is in possession of undisclosed inside information regarding that company. The Corporations Act imposes substantial penalties on persons who breach those provisions. Trading in breach of these provisions is referred to as 'insider trading'.

• 1.2 This policy has been developed to help all directors and team members (you or your) understand insider trading and their obligations under Australian law.

• 1.3 It applies to directors and team members of Vita Group and of any of its subsidiaries.

• 1.4 During your career with Vita Group you may become aware of information that could have an impact on the price of shares and other financial products in the market. This information could be 'inside information'.

• 1.5 This information is usually confidential and subject to your duties of confidence to the Company and to customers. The insider trading rules in the Corporations Act also affect how you can use this information.

• 1.6 As well as potentially serious civil and criminal liability arising from breaches of insider trading laws, insider trading is also a serious breach of conditions of employment within Vita Group and may lead to disciplinary action up to and including dismissal.

• 1.7 This policy is not intended to be a substitute for you obtaining your own legal advice. If you have any particular concerns on insider trading you should speak with your manager or the Company Secretary.

2.

Definitions

2.1

Designated Team Member: Team members having access to regular confidential communications (including but not limited to Vita Group channel or consolidated monthly management reports and forecasts) and any other team members nominated by the CEOs, are Designated Team Members.

• 2.2 Financial Products: The following are Financial Products:

  • (a) securities - including a company's shares, debentures

    (including convertible notes), managed investment interests made available by it, units of shares or of managed investment interests and exchange traded and over the counter put and call options over any of those securities,

  • (b) derivatives - including exchange traded options, equity swaps, futures or options, equity futures or other futures which relate to any financial products of a company,

  • (c) managed investment products,

  • (d) superannuation products, and

  • (e) any other financial product that can be traded on a financial market (that is, tradeable on a stock exchange or futures exchange or other type of licensed financial market).

• 2.3 Information: Information means any fact, matter or circumstance and includes:

  • (a) matters of supposition (eg, rumours or innuendo) or which are otherwise insufficiently definite to warrant being made known to the public, and

  • (b) matters relating to the intentions, or likely intentions, of a person. such further duties as are from time-to-time delegated by the Board.

  The information can be in any form (eg, written or verbal).

• 2.4 Inside Information: Inside Information means confidential information concerning the company's financial position, strategy or operations and any other information that a reasonable person might consider, if it were made public, would be likely to have a material impact on a decision to buy or sell the company's financial products. You may come into possession of inside information if you become aware of any of the following when it is not generally available:

  • (a) actual profit results,

  • (b) internal forecasts of profit results,

  • (c) changes of strategic direction of the business,

  • (d) details of a new discovery, new product or substantial new business contract,

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