Northern Iron

The Board has adopted a policy and procedure on dealing in the Company’s securities by directors, officers and employees which prohibits dealing in the Company’s securities when those persons possess inside information.

1. Directors, officers and employees who wish to trade in company securities must first have regard to the statutory provisions of the corporations act dealing with insider trading

   Insider trading is the practice of dealing in a company's securities (ie. shares or options) by a person with some connection with a company (eg an employee) in possession of information generally not available to the public, but may be relevant to the value of the company's securities. It may also include the passing on of this information to another.Legally, it is an offence which carries severe penalties, including imprisonment.

2. The company identifies the circumstances set out below, in addition to the circumstances set out in the Corporations Act, where directors, officers and employees of the company may not trade in the company’s securities:
   

   A director, officer or employee of the Company should not deal in any of the securities of the Company at any time when he or she is in possession of unpublished price-sensitive information in relation to those securities.

3. Directors must notify the Company Secretary once trading in the company's securities has occurred. The Company Secretary will then immediately circulate such details to the other directors and lodge an Appendix 3Y with ASX.

4. Directors and officers should not engage in short term trading in the company’s securities, which is defined as less than a 30 day period between purchase and sale.

5. Directors must advise the Chairman prior to any proposed transaction in the Company’s securities, and in the case of the Chairman he must advise the Chief Executive Officer. In either case the Company Secretary should be informed and he should notify the other directors of the proposed transaction.

Directors will normally be permitted to trade in the Company’s securities provided that:

• The director is not in the possession of inside information
• The trading is not for short term speculative gain
• The trading is not likely to be seen by the public, press, other shareholders or ASX to be unfair or inappropriate