Revised Securities Trading Policy
Released
Released
Announcement PDF
Emyria ASX Announcement | 7 September2026 1
ASX RELEASE.
7 September 2026
REVISED SECURITIES TRADING POLICY
Emyria Limited (ASX: EMD) (“Emyria”, or the “Company”) advises that it has revised its
Securities Trading Policy, a copy of which is attached for release to the market.
This announcement was authorised for release to the ASX by the Board of Emyria Limited.
For further information, investment opportunities, or more about Emyria’s approach to
mental health treatment, please contact:
Greg Hutchinson
Executive Chair
1300 436 363 | investors@emyria.com
ASX RELEASE.
Emyria ASX Announcement | 7 September2026 2
Risks associated with the use of MDMA, MDMA-inspired compounds and psilocybin
All medicines carry risks and specialist prescribers, such as registered psychiatrists, are best placed to assess
the suitability of a new medication against a patient’s individual circumstances and medical history before
proceeding. Adverse effects of MDMA include high blood pressure, increased pulse rate, faintness, and panic
attacks, and in some rare cases it can cause loss of consciousness or trigger seizures. Other side effects include
involuntary jaw clenching, decreased appetite, restless legs, nausea, headache, sweating and muscle/joint
stiffness. Adverse effects of psilocybin can include temporary increase in blood pressure and a raised heart rate.
There may be some risk of psychosis in predisposed individuals. The effects of MDMA and psilocybin are
unlikely at low doses in the treatment regimens used in psychedelic-assisted psychotherapy while
appropriately managed in a controlled environment with direct medical supervision. The risk profile of the
MDMA inspired compounds is currently unknown.
The availability of these products is subject to the safety and efficacy of the products being tested through
clinical trials. Emyria makes no representations or warranties as to the safety or efficacy of the products or the
products’ ability (or the ability of its key compounds) to be used in the treatment of indications such as PTSD.
There are currently no approved products containing MDMA, psilocybin or MDMA inspired compounds that
the TGA has evaluated for quality, safety and efficacy.
Emyria Limited develops and delivers new treatments for mental health and select neurological
conditions through an integrated model of direct clinical services and treatment development:
Emyria Healthcare: Evidence-based treatment for patients not finding relief
from conventional care while also helping evaluate emerging new therapies like
assisted therapy for PTSD and assisted therapy for treatment-resistant depression.
Emyria Data: Robust and ethically sourced Real-World Data gathered with patients
to improve Emyria’s unique therapy and drug development programs.
Emyria’s Pipeline: New psychedelic-assisted therapies and drug treatments for mental
health and select neurological diseases.
EMYRIA’S INTERACTIVE INVESTOR HUB
Investorhub.emyria.com Interact with Emyria’s announcements and
updates by asking questions and comments, which our team can respond
to where possible.
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Securities Trading Policy
1. Introduction
1.1 Purpose
(a) This document sets out the Company’s policy regarding its directors, officers,
employees, consultants and contractors (irrespective of location) who Deal or may
Deal in Company Securities and should be read in its entirety.
(b) The purpose of this Policy is to:
(i) provide a summary of the law on insider trading in Australia;
(ii) outline the prohibitions on dealing in Company Securities to prevent the
misuse of unpublished information which could materially affect the value
of such securities;
(iii) ensure that the reputation of the Company, its directors, officers,
employees, consultants and contractors is not adversely impacted by
perceptions of Dealing in Company Securities at inappropriate times; and
(iv) achieve high standards of corporate conduct and support market
confidence in the integrity of Dealing in Company Securities.
1.2 Source of legal obligations
The sources of legal obligations underpinning this Policy include:
(a) the Corporations Act, which, among other things, prohibits insider trading by
anyone (regardless of geographical location); and
(b) the ASX Listing Rules, ASX Guidance Note 27 (Trading Policies) and ASX
Corporate Governance Principles and Recommendations, which set out
requirements for responsible trading in listed company shares.
2. Insider trading prohibition – the law
2.1 General prohibition
The Corporations Act prohibits a person, while in possession of Inside Information from
(see clause 2.2 below):
(a) Dealing in Company Securities;
(b) procuring another person to Deal in Company Securities; or
(c) communicating Inside Information or causing Inside Information to be
communicated, directly or indirectly, to another person who will, or are likely to,
Deal on the Inside Information.
The Corporations Act imposes substantial penalties on persons who breach those
provisions and applies to the extent of any inconsistency between it and this Policy.
The requirements imposed by this Policy are in addition to any legal prohibitions on insider
trading. A person who possesses Inside Information is prohibited from trading and this
applies even where:
(a) the Dealing occurs outside a Black-out Period;
(b) the Dealing falls within an exclusion in this Policy; or
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(c) Disposal Consent has been given under this Policy (whether in exceptional
circumstances or otherwise).
2.2 Possession of Inside Information
An individual is responsible for assessing whether they possess “Inside Information”. This
occurs where:
(a) the person possesses information that is not generally available to the public and,
if the information were generally available, a reasonable person would expect it to
have a material effect on the price or value of Company Securities (or a decision
whether or not to trade in them); and
(b) the person knows, or ought reasonably to know, that the information is not
generally available and, if it were generally available, a reasonable person would
expect it to have a material effect on the price or value of Company Securities (or
a decision whether or not to trade in them).
For the purposes of clause 2.2(b), a reasonable person would be taken to expect
information to have a material effect on the price or value of securities if the information
would, or would be likely to, influence a person who commonly invests in securities to
either deal or not deal in securities in any way.
2.3 Employee Incentive Schemes
The insider trading prohibitions under the Corporations Act do not apply to certain Dealings
in Company Securities under a scheme established solely or primarily for the benefit of the
employees of the Company or its related bodies corporate (an Employee Incentive
Scheme).
This Policy therefore does not apply to:
(a) an application for Company Securities under an Employee Incentive Scheme by a
person who is an employee of the Company or a body corporate that is related to
the Company, or a trustee for such a person; or
(b) an acquisition of Company Securities under such an application.
The insider trading prohibitions do apply to the sale of Company Securities acquired under
an Employee Incentive Scheme. Accordingly, any Dealing in Company Securities acquired
under an Employee Incentive Scheme is subject to this Policy.
The exception to the insider trading prohibition for Employee Incentive Schemes is limited
in scope. Employees are cautioned against relying on this exception without having
obtained independent advice.
3. Dealing in Company Securities
3.1 When a Designated Person MAY Deal
A Designated Person may Deal in Company Securities unless restricted from doing so
under clause 3.2 (When a Designated Person May Not Deal).
3.2 When a Designated Person MAY NOT Deal
(a) Subject to clause 5 (Exceptions), a Designated Person may not Deal in Company
Securities during the following designated Black-out Periods:
(i) the period two weeks prior to, and 24 hours after the release of the
Company’s quarterly results;
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(ii) the period two weeks prior to, and 24 hours after the release of the
Company’s half-year results;
(iii) the period two weeks prior to, and 24 hours after the release of the
Company’s full-year results; and
(iv) any other period determined by the Chair in consultation with the
Company Secretary to be a Black-out Period from time to time.
(b) In addition to the restrictions in clause 3.2(a), a Designated Person may not Deal
in Company Securities at any time if he or she has:
(i) information that he or she knows, or ought reasonably to know, is Inside
Information; or
(ii) not complied with clause 6 (Notice of Dealing in Company Securities).
3.3 When employees, consultants or contractors (other than a Designated Person) MAY
Deal
An employee, consultant or contractor (who is not a Designated Person) may, at any time,
Deal in Company Securities if he or she does not have information that he or she knows,
or ought reasonably to know, is Inside Information.
3.4 When employees, consultants or contractors (other than a Designated Person) MAY
NOT Deal
An employee, consultant or contractor (who is not a Designated Person) who has
information that he or she knows, or ought reasonably to know, is Inside Information may
not Deal in Company Securities.
4. Ad-hoc restrictions
The Company may impose, without notice and in its sole and absolute discretion,
additional restrictions on Dealing in Company Securities by any or all Designated Persons
as the Company considers appropriate. For the avoidance of doubt, the Company may
impose ad-hoc restrictions under this clause even where the proposed Dealing would
otherwise take place outside a Black-out Period provided for in this Policy. Any restriction
communicated by the Company to any or all Designated Persons under this clause must
be kept strictly confidential.
5. Exceptions
5.1 Permitted dealings
Subject to not being in the possession of Inside Information, a Designated Person may at
any time:
(a) transfer Company Securities already held into a superannuation fund or other
saving scheme in which the Designated Person is a beneficiary;
(b) invest in, or trade in units of, a fund or other scheme (other than a scheme only
investing in Company Securities) where the assets of the fund or scheme are
invested at the discretion of a third party;
(c) undertake to accept, or accept, a takeover offer;
(d) participate in an offer or invitation made to all or most security holders, including a
rights issue, equal access buy-back, security purchase plan or dividend or
distribution reinvestment plan, where the timing and structure of the offer or
invitation has been approved by the Board. This includes decisions relating to
whether or not to take up the entitlements and sale of entitlements required to
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provide for the take up of the balance of entitlements under a renounceable pro
rata issue;
(e) exercise (but not Deal with the Company Securities following exercise) an option
or right under an employee incentive scheme during a Black-out Period;
(f) acquire (but not Deal with the Company Securities following acquisition) Company
shares by conversion of financial instruments giving rights to conversion to shares
(eg. options or convertible securities) where the final date for the conversion of the
Company Security falls during a Black-out Period or the Company has had a
number of consecutive Black-out Periods and the Designated Person could not
reasonably have been expected to exercise it at a time when free to do so;
(g) acquire Company Securities under a bonus issue made to all holders of securities
of the same class;
(h) acquire Company Securities under a dividend reinvestment, or top-up plan that is
available to all holders of securities of the same class;
(i) acquire, or agree to acquire, Company Securities through the exercise of
Company Securities issued under an employee incentive scheme. However, any
Dealing in those Company Securities remains subject to this Policy and the
provisions of the Corporations Act;
(j) withdraw ordinary shares in the Company held on behalf of the Designated Person
in an employee incentive scheme where the withdrawal is permitted by the rules of
that plan; and
(k) where the Designated Person is a trustee, trade in Company Securities by that
trust, provided the Designated Person is not a beneficiary of the trust and any
decision to trade during a Black-out Period is taken by the other trustees or by the
investment managers independently of the Designated Person.
5.2 Approval to dispose or transfer Company Securities in exceptional circumstances
(a) In exceptional circumstances a Designated Person may seek written approval
from the Chair (Approval Officer) to dispose of or transfer (but not acquire or
otherwise Deal with) Company Securities during a Black-out Period (Disposal
Consent).
(b) The Approval Officer will act with caution in determining whether there are
exceptional circumstances, which may include, but will not be limited to, where:
(i) the Designated Person is in severe financial hardship and a pressing
financial commitment cannot be satisfied otherwise than by disposing of
Company Securities; or
(ii) the Designated Person is required by a court order, or there are court
enforceability undertakings, to transfer or dispose of Company Securities
or there is some other overriding legal regulatory requirement for them to
do so.
(c) A Designated Person seeking Disposal Consent based on clause 5.2(b)(i) must
provide the Approval Officer with:
(i) a written application stating all of the facts; and
(ii) copies of relevant supporting documentation, including contact details of
the Designated Person’s accountant, bank and other such independent
institutions (where applicable).
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(d) A Designated Person seeking Disposal Consent based on clause 5.2(b)(ii) must
provide the Approval Officer with a written application accompanied by relevant
court and/or supporting legal documentation (where applicable).
(e) Any decision to grant or refuse to grant Disposal Consent by the Approval Officer:
(i) may be made only if that Designated Person is not in possession of Inside
Information;
(ii) may be made in the Approval Officer’s absolute discretion, without giving
any reasons;
(iii) can be withdrawn (if clearance has been given) if new information comes
to light or there is a change in circumstances;
(iv) is final and binding on the Designated Person seeking clearance;
(v) must be kept strictly confidential by the Designated Person and not
disclosed to any other person; and
(vi) may be made on such terms and conditions (including the duration of the
right to dispose or transfer) as considered reasonable in the
circumstances by the Approval Officer.
(f) In deciding whether to grant Disposal Consent, the Approval Officer will consider
the need to minimise the risk of insider trading, and also to avoid the appearance
of insider trading and the significant reputational damage that may cause.
(g) The Approval Officer will notify the Board of any Disposal Consent granted to a
Designated Person.
(h) A Disposal Consent, if granted, will be issued in writing to the Designated Person
and will contain a specified time period during which the disposal or transfer can
be made.
(i) Any Disposal Consent granted under clause 5.2(e) is not an endorsement to
dispose of or transfer Company Securities. The Designated Person doing the
trading is individually responsible for their investment decisions and their
compliance with insider trading laws. The Designated Person must carefully
consider whether they are in possession of any Inside Information that might
preclude them from trading at that time. If the Designated Person is in any doubt,
they should not trade.
(j) If a Designated Person comes into possession of Inside Information after receiving
a Disposal Consent, they must not trade despite having received the consent.
6. Approval and notification requirements
6.1 Approval requirements
(a) Any Designated Person (other than the Chair) wishing to Deal in Company
Securities must obtain the prior written approval of the Chair or the Board before
doing so.
(b) If the Chair wishes to Deal in Company Securities, the Chair must obtain the prior
approval of the Board before doing so.
6.2 Approvals to Deal
(a) All requests to Deal in Company Securities as referred to in clause 6.1 must:
(i) include the intended volume of Company Securities to be Dealt in and an
estimated time frame for the Dealing; and
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(ii) confirm that the Designated Person is not in possession of Inside
Information.
(b) Copies of written approvals must be forwarded to the Company Secretary prior to
the approved Dealing.
6.3 Notification
(a) Subsequent to approval obtained in accordance with clause 6.2, any Designated
Person who Deals in Company Securities must:
(i) notify the Company Secretary in writing of the details of the transaction
within five business days of the Dealing occurring; and
(ii) notify the Company Secretary in writing if they begin to have, or cease to
have, a “substantial holding” (as defined in section 9 of the Corporations
Act) in the Company, or if they have a substantial holding in the Company
and there is a movement of at least 1% in their holding.
(b) The notification obligation in clause 6.3(a) operates at all times but does not apply
to acquisitions of shares or options by employees made under employee share or
option schemes, nor does it apply to the acquisition of shares as a result of the
exercise of options under an employee share scheme.
7. Other restrictions
7.1 Incomplete Buy or Sell Orders
(a) Buy or sell orders for Company Securities which are placed but not completed
outside of a Black-out Period are subject to the following restrictions once the
Black-out Period commences:
(i) the order must be completed within five trading days otherwise it will
lapse; and
(ii) the order cannot be varied.
(b) Any order subject to this procedure should be notified in writing to the Company
Secretary within 24 hours of the Black-out Period commencing.
7.2 Derivatives
(a) The Company prohibits the use of Derivatives in relation to unvested equity
instruments, including performance share rights, and vested Company Securities
that are subject to disposal restrictions (such as a ‘Holding Lock’).
(b) Derivatives may be used in relation to vested positions which are not subject to
disposal restrictions subject to compliance with the law and the other provisions of
this Policy.
7.3 No speculative trading
Under no circumstances should Designated Persons engage in short-term or speculative
trading in Company Securities. This prohibition includes short term direct dealing in
Company Securities as well as transactions in the derivative markets, involving exchange
traded options, share warrants, contracts for difference, and other similar instruments,
which are short term or speculative.
7.4 No protection arrangements
The entering into of all types of “protection arrangements” for any Company Securities:
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(a) is prohibited at any time in respect of any Company Securities which are unvested
or subject to a holding lock; and
(b) otherwise, requires approval under clause 6.
For the avoidance of doubt and without limiting the generality of this Policy, entering into
protection arrangements includes entering into transactions which:
(c) amount to “short selling” of Company Securities beyond the Designated Person’s
securities;
(d) operate to limit the economic risk of any Designated Person’s security holding
(e.g. hedging arrangements) including Company Securities held beneficially (for
example, in trust or under an incentive plan) on that Designated Person’s behalf;
or
(e) otherwise enable a Designated Person to profit from a decrease in the market
price of securities.
7.5 Prohibition on Margin Loan Arrangements
Designated Persons may not:
(a) enter into a Margin Loan or similar funding arrangement to acquire any Company
Securities; or
(b) use Company Securities as security for a Margin Loan or similar funding
arrangement.
7.6 Securities of other companies
The prohibitions in the Corporations Act against insider trading applies equally to where
Inside Information is being held by a person about another listed company or entity. This
may occur, for example, where in the course of negotiating a transaction with the
Company, another listed entity provides confidential information about itself or another
listed entity. Accordingly, if a person possesses Inside Information in relation to the
securities of another listed entity, they must not Deal in those securities.
8. Penalties
(a) Insider trading is a criminal offence. A person who commits a breach of the insider
trading provisions could be subject to both civil and criminal penalties for the
individual and for the Company.
(b) In addition, the insider trader, and any other persons involved in the contravention,
may also be liable to compensate third parties for any resulting loss.
9. Policy compliance
(a) During the year the Company may require confirmation from Designated Persons
that they have complied with this Policy. The Company may also require
confirmation (or declarations) of holdings in securities. All such requested
information must be supplied within five business days of the request being made.
(b) A breach of this Policy will be regarded as serious misconduct and may lead to
disciplinary action being taken (including termination of employment). If the
Company becomes aware of any breach of this Policy, then the Company may
report such breach to the Australian Securities and Investments Commission.
10. ASX Notifications
(a) The Company must notify ASX within 5 business days after any change to a
director’s relevant interest in Company Securities or a related body corporate of
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the Company, including whether the change occurred inside a Black-out Period
and, if so, whether prior written clearance was provided.
(b) To enable the Company to comply with the obligation set out in clause 10(a), a
director must immediately (and no later than 3 business days after any relevant
event) notify the Company Secretary in writing of the requisite information for the
Company Secretary to make the necessary notifications to the Australian
Securities and Investments Commission and ASX as required under the
Corporations Act and ASX Listing Rules.
(c) If the Company makes a material change to this Policy, the amended Policy will be
provided to the ASX for release to the market within 5 business days of the
material changes taking effect.
11. Who to contact
If an individual is in any doubt regarding their proposed dealing in securities, they should
contact the Company Secretary.
12. Publication
This Policy will be made available from the Company website.
13. Review
This policy shall be reviewed annually by the Board to ensure that it is operating effectively
and ascertain whether changes are required to the policy.
14. Defined terms
For the purposes of this Policy:
Black-out Periods means those periods detailed in clause 3.2(a) and any other
period determined by the Chair in consultation with the Company
Secretary when Designated Persons may not Deal in Company
Securities.
Company means Emyria Limited (ACN 625 085 734).
Company
Securities
includes shares, options, performance rights, warrants,
derivatives and interests in shares (including vested or unvested
options and vested or unvested performance rights) linked in any
way to the underlying price of shares in the Company.
Corporations Act means the Corporations Act 2001 (Cth), as amended or modified
from time to time.
Deal or Dealing includes:
(a) applying for, acquiring or disposing of securities;
(b) entering into an agreement to apply for, acquire or
dispose of securities; and
(c) granting, accepting, acquiring, disposing, exercising or
discharging an option or other right or obligation to
acquire or dispose of securities,
or procuring another person to do any action referred to in
paragraphs (a), (b) or (c) above.
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Derivatives include:
(d) derivatives within the meaning given in section 761D of
the Corporations Act (such as options, forward contracts,
swaps, futures, warrants, caps and collars); and
(e) any other transaction in financial products which operate
to limit (in any way) the economic risk associated with
holding the relevant securities.
Designated
Persons
means each of:
(a) the Directors of the Company;
(b) Key Management Personnel (as defined in the
Corporations Act), including (without limitation) the Chief
Executive Officer, the Chief Financial Officer, the Chief
Operating Officer and the Company Secretary and their
direct reports;
(c) any other person who, directly or indirectly, has the
authority and responsibility for planning, directing and
controlling the activities of the Company;
(d) any other person the Board of Directors designate as a
Designated Person in writing;
(e) in relation to those persons identified in paragraphs (a),
(b), (c) and (d) above, the following people are also
deemed to be Designated Persons:
(i) their spouse (including a de facto spouse) or any
of their children (including a step-child or
adopted child) under the age of 18 years;
(ii) a person financially dependent on or acting in
concert with any of those persons; and
(iii) a trust or company which they or any close
family members control or have an interest in.
Inside Information means information which is not generally available to the market
and, if it were generally available to the market, would be likely to
have a material effect on the price or value of securities.
Annexure A provides further details about what constitutes Inside
Information.
Margin Loan means any lending or similar arrangement allowing a person to
borrow money to invest in securities using existing investments
as security.
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Annexure A – Inside Information
1. Inside information
Inside Information means information which is not generally available to the market and, if
it were generally available to the market, would be likely to have a material effect on the
price or value of securities.
2. Information that is generally available
(a) Information is considered to be generally available if:
(i) it consists of readily observable matter; or
(ii) it has been made known in a manner likely to bring it to the attention of
investors in securities and a reasonable period for dissemination of that
information has elapsed; or
(iii) it may be deduced, inferred or concluded from the above.
(b) Information will be generally available if it has been released to the ASX, published
in an annual report or prospectus or otherwise been made generally available to
the investing public and a reasonable period of time has elapsed after the
information has been disseminated in one of these ways.
(c) For the purposes of the insider trading provisions of the Corporations Act,
information is defined broadly and includes matters of supposition and other
matters which are insufficiently definite to warrant being made known to the public.
It also includes matters relating to the intentions of a person.
3. Material effect on the price of securities
(a) Information is considered by the Corporations Act to be likely to have a material
effect on the price or value of securities of a company if the information would, or
would be likely to, influence persons who commonly invest in securities in deciding
whether or not to subscribe for, buy or sell those securities.
(b) It is not possible to list all of information that may be material, however, the
following type of information would be likely to be considered to have a material
effect on the Company’s share price:
(i) information regarding a material increase or decrease in the Company’s
financial performance from previous results or forecasts, such as changes
to profit results;
(ii) a proposed material business or asset acquisition or sale;
(iii) the damage or destruction of a material operation of the Company;
(iv) proposed material legal proceedings to be initiated by or against the
Company;
(v) regulatory action or investigations undertaken by a government authority;
(vi) the launch of a new business or material new product; or
(vii) a proposal to undertake a new issue of securities or major change in
financing.
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