revision 5 september 221 lamprell share dealing code

Lamprellshare dealing

Code

Revision 5 | September 2021

This document is in the custody of theGroup General Counsel & Company Secretary

https://www.lamprell.com/

LAMPRELL SHARE DEALING CODE

3

l a m p r e l l . c o m

2

Contents

Introduction 4

Part A - clearance procedures 4

Part B - additional provisions for PDMRS 5

Schedule 1 - defined terms 8

APPENDIX 1 10

Letter to PDMRS relating to notifications

of dealings (plus letter to connected persons) 10

APPENDIX 2 14

Letter to permanent insiders 14

Letter to project insiders 15

Template request for authorisation form 16

Template notification of dealings form 18



54


Introduction

The Purpose of this Code is to ensure that

the Directors of Lamprell plc (the Company),

and certain employees of the Company

and its subsidiaries, do not abuse or place

themselves under suspicion of abusing

Inside Information, and comply with

their obligations under the Market Abuse

Regulation.

Part A of this Code contains the Dealing

clearance procedures which must be

observed by the Company’s Person

Discharging Management Responsibilities

(PDMRs) and those employees who have

been told that the clearance procedures

apply to them. This means that there will

be certain times when such persons cannot

Deal in Company Securities.

Part B sets out certain additional obligations

which only apply to PDMRs.

Failure by any person who is subject to

this Code to observe and comply with its

requirements may result in disciplinary

action. Depending on the circumstances,

such non-compliance may also constitute a

civil and/or criminal offence.

Schedule 1 sets out the meaning of

capitalised words used in this Code, and it

is recommended you familiarise yourself

with them while reading this document.

Part A - clearance procedures

Dealing by restricted persons

If you are a Director of the Company or are

informed in writing that you are a PDMR,

you will be a ‘Restricted Person’ for the

purposes of this Code. As a Restricted

Person you must not deal in the Company’s

Shares without obtaining clearance to deal in

advance in accordance with paragraph 2 of

this Code.

Clearance to deal

You must not Deal for yourself or for anyone

else, directly or indirectly, in Company

Securities without obtaining clearance from

the Company in advance.

a. Applications for clearance to

deal must be made in writing and

submitted to the Company Secretary

using the template form ‘Template

Request for Authorisation Form’ set

out in Appendix 2.

b. You must not submit an application

for clearance to Deal if you are in

possession of Inside Information.

If you become aware that you are

or may be in possession of Inside

Information after you submit an

application, you must inform the

Company Secretary as soon as

possible and you must refrain from

Dealing (even if you have been given

clearance).

c. You will receive a written response to

your application, normally within five

business days from submission. The

Company will not normally give you

reasons if you are refused permission

to Deal. You must keep any refusal

confidential and not discuss it with any

other person.

d. If you are given clearance, you must

Deal as soon as possible and in any

event within two business days of

receiving clearance.

e. Clearance to Deal may be given

subject to conditions. Where this is

the case, you must observe those

conditions when Dealing.

f. You must not enter into, amend or

cancel a Trading Plan or an Investment

Programme under which Company

Securities may be purchased or sold

unless clearance has been given to do

so.

g. Different clearance procedures will

apply where Dealing is being carried

out by the Company in relation to

an employee share plan (e.g. if the

Company is making an option grant

or share award to you, or shares

are receivable on vesting under

a long-term incentive plan). You

will be notified separately of any

arrangements for clearance if this

applies to you.

h. If you act as the trustee of a trust,

you should speak to the Company

Secretary about your obligations in

respect of any Dealing in Company

Securities carried out by the trustee(s)

of that trust.

i. You should seek further guidance

from the Company Secretary before

transacting in:

• units or shares in a collective

investment undertaking (e.g. a UCITS

or an Alternative Investment Fund)

which holds, or might hold, Company

Securities; or

• financial instruments which provide

exposure to a portfolio of assets which

has, or may have, an exposure to

Company Securities.

This is the case even if you do not intend to

transact in Company Securities by making

the relevant investment.

Part B - additional provisions for PDMRS

Circumstances for refusal

You will not ordinarily be given clearance

to Deal in Company Securities during any

period when there exists any matter which

constitutes Inside Information or during a

Closed Period.

Notification of transactions

a. You must notify the Company and the

Financial Conduct Authority (FCA) in

writing of every Notifiable Transaction

in Company Securities conducted for

your account as follows:



76


• Notifications to the Company must be

made using the template ‘Template

Notification Of Dealings Form’ below

and sent to the Company Secretary as

soon as practicable and in any event

within one business day. You should

ensure that your investment managers

(whether discretionary or not) notify

you of any Notifiable Transactions

conducted on your behalf promptly so

as to allow you to notify the Company

within this time frame.

• Notifications to the FCA must be

made within three business days of

the transaction date. A copy of the

notification form is available on the

FCA’s website.

b. If you are uncertain as to whether

or not a particular transaction is a

Notifiable Transaction, you must

obtain guidance from the Company

Secretary.

PCAS and investment managers

a. You must provide the Company with

a list of your PCAs and notify the

Company of any changes that need to

be made to that list.

b. You should ask your PCAs not to

Deal (whether directly or through an

investment manager) in Company

Securities during Closed Periods and

not to deal on considerations of a

short-term nature. A sale of Company

Securities which were acquired

less than a year previously will be

considered to be a Dealing of a short-

term nature.

c. Your PCAs are also required to

notify the Company and the FCA in

writing, within the time frames given

in paragraph 2, of every Notifiable

Transaction conducted for their

account. You should inform your PCAs

in writing of this requirement and keep

a copy; the Company Secretary will

provide you with a letter that you can

use to do this. A copy of the form for

notifying the FCA is available on the

FCA’s website. You should ask your

investment managers (whether or not

discretionary) not to Deal in Company

Securities on your behalf during

Closed Periods.



98


Schedule 1 - defined terms

Closed Period means any of the following:

• the period of 60 calendar days

before the release of the preliminary

announcement of the Company’s

annual results (or, where no such

announcement is released, up to the

publication of the Company’s annual

financial report) or, if longer, the

period from the end of the relevant

financial year up to such release (or

publication); and

• the period of 60 calendar days before

the release of the Company’s half-

yearly financial report or, if longer, the

period from the end of the relevant

financial period up to such release.

Company Securities means any publicly

traded or quoted shares or debt instruments

of the Company (or of any of the Company’s

subsidiaries or subsidiary undertakings) or

derivatives or other financial instruments

linked to any of them, including phantom

options.

Dealing (together with corresponding terms

such as ‘Deal’ and ‘Deals’) means any type of

transaction in Company Securities, including

purchases, sales, the exercise of options, the

receipt of shares under share plans, using

Company Securities as security for a loan or

other obligation and entering into, amending

or terminating any agreement in relation to

Company Securities (e.g. a Trading Plan).

FCA means the UK Financial Conduct

Authority.

Inside Information means information which

relates to the Company or any Company

Securities, which is not publicly available,

which is likely to have a non-trivial effect on

the price of Company Securities and which

an investor would be likely to use as part of

the basis of his or her investment decision.

Investment Programme means a share

acquisition scheme relating only to the

Company’s shares under which: (A) shares

are purchased by a Restricted Person

pursuant to a regular standing order or

direct debit or by regular deduction from

the person’s salary or director’s fees; or (B)

shares are acquired by a Restricted Person

by way of a standing election to re-invest

dividends or other distributions received;

or (C) shares are acquired as part payment

of a Restricted Person’s remuneration or

director’s fees.

Market Abuse Regulation means the EU

Market Abuse Regulation (596/2014).

Notifiable Transaction means any

transaction relating to Company Securities

conducted for the account of a PDMR

or PCA, whether the transaction was

conducted by the PDMR or PCA or on his

or her behalf by a third party and regardless

of whether or not the PDMR or PCA had

control over the transaction. This captures

every transaction which changes a PDMR’s

or PCA’s holding of Company Securities,

even if the transaction does not require

clearance under this Code. It also includes

gifts of Company Securities, the grant of

options or share awards, the exercise of

options or vesting of share awards and

transactions carried out by investment

managers or other third parties on behalf

of a PDMR, including where discretion is

exercised by such investment managers or

third parties and including under Trading

Plans or Investment Programmes.

PCA means a person closely associated with

a PDMR, being:

a. the spouse or civil partner of a PDMR;

or

b. a PDMR’s child or stepchild under the

age of 18 years who is unmarried and

does not have a civil partner; or

c. a relative who has shared the same

household as the PDMR for at least

one year on the date of the relevant

Dealing; or

d. a legal person, trust or partnership,

the managerial responsibilities of

which are discharged by a PDMR (or

by a PCA referred to in paragraphs

(a), (b), or (c) of this definition), which

is directly or indirectly controlled by

such a person, which is set up for the

benefit of such a person or which

has economic interests which are

substantially equivalent to those of

such a person.

PDMR means a person discharging

managerial responsibilities in respect of the

Company, being either:

a. director of the Company; or

b. any other employee who has been

told that he or she is a PDMR.

Restricted Person means:

a. a PDMR; or

b. any other person who has been told

by the Company that the clearance

procedures in Part A of this Code

apply to him or her.

Trading Plan means a written plan

entered into by a Restricted Person and

an independent third party that sets out a

strategy for the acquisition and/or disposal

of Company Securities by the Restricted

Person, and:

a. specifies the amount of Company

Securities to be dealt in and the price

at which and the date on which the

Company Securities are to be dealt in;

or

b. gives discretion to that independent

third party to make trading decisions

about the amount of Company

Securities to be dealt in and the price

at which and the date on which the

Company Securities are to be dealt in;

or

c. includes a method for determining the

amount of Company Securities to be

dealt in and the price at which and the

date on which the Company Securities

are to be dealt in.



1110


APPENDIX 1

Letter to PDMRS relating to notifications of dealings (plus letter to connected persons)

[TO BE PLACED ON LAMPRELL plc LETTERHEAD]

TO: [Name of persons discharging

managerial responsibilities] [Address]

[Date]

Requirement to disclose dealings in

Lamprell plc’s shares and related financial

instruments pursuant to the Market Abuse

Regulation

Dear [name of individual]

Obligations are imposed on directors and

certain senior executives of listed companies

to disclose dealings in the shares and

related financial instruments of those listed

companies. The obligations also extend to

certain individuals and bodies corporate

connected to those directors and senior

executives.

These obligations are contained in the

Market Abuse Regulation (MAR). Lamprell

plc (the Company) has a number of

obligations under MAR including drawing

up and maintaining a list of all persons

discharging managerial responsibilities and

those persons closely associated with them

(PCAs). [As a director of the Company,

you are a person discharging managerial

responsibilities and MAR also applies to

you/We have decided that the disclosure

of dealings obligations contained in MAR

also apply to you as a senior executive of

the Company]. The purpose of this letter

is to explain the nature of your disclosure

obligations with which you and persons

closely associated with you (PCAs) need to

comply.

Any failure to make the necessary

disclosures under MAR may result in the FCA

taking action against you personally. The

FCA can impose an unlimited fine or publicly

censure any individual who breaches MAR.

In addition, we may consider any failure

to comply with these requirements as a

disciplinary matter.

Disclosure requirement

MAR requires you to disclose to the

Company any transactions conducted on

your own account in the shares, derivatives

or other financial instruments related to

shares of the Company. You are required to

disclose these transactions within 2 business

days of the date of the transaction.

This notification obligation is in addition

to any obligations under Chapter 5 of the

Disclosure Guidance and Transparency Rules

(Notification of the acquisition or disposal

of major shareholdings) applicable to the

disclosure of voting rights in respect of the

Company’s shares of 3% or more.

A notification form is available at [∞ ]for

this purpose. You should ensure that you

complete all the boxes as accurately and

completely as possible. Please send your

notification form to [name of relevant

individual] within 2 business days of the date

on which the transaction occurred.

You must also notify the FCA using the

online form linked below within 2 business

days of the date on which the transaction

occurred.

https://marketoversight.fca.org.uk/

electronicsubmissionsystem/MaPo_PDMR_

Introduction

Please contact Company Secretary if

you require assistance in completing the

notification form.

Types of transaction and financial instruments

You are required to disclose any transactions

conducted on your account (whether by

you or an intermediary) in the shares or

derivatives or financial instruments related

to the shares of the Company. For example,

this would cover any options over shares of

the Company or a spread bet on the price of

the shares.

You should consider the types of

transactions to be caught by your disclosure

obligations in the widest sense and not

just sales and purchases of shares. Non-

exhaustive lists of the kinds of transactions

that must be notified are set out the

memorandum attached at Attachment 1 to

this letter.

If you are in any doubt as to whether a

transaction that you propose to conduct in

the securities of the Company is caught by

this notification requirement, please contact

Company Secretary before proceeding with

the transaction.

Obligations on your connected persons

The Disclosure Rules also require certain

individuals and bodies corporate who are

connected to you within the meaning of

Schedule 11B to disclose any transactions

conducted on their own account in the

shares, derivatives and other financial

instruments related to the shares of the

Company. This obligation to disclose

dealings falls on the connected person

personally. Consequently, we require you

to inform your connected persons that they

are connected to you for the purposes of

the Disclosure Rules. In order to explain the

obligations to them, we have provided you

with a letter from you to your connected

persons setting out their obligations in

Attachment 2 of this letter.

Any of the following people will be

considered to be a person closely associated

to you for the purposes of MAR:

a. your spouse or civil partner;

b. your child or step-child under the age

of 18 years who is unmarried and does

not have a civil partner;

c. any relative who has shared the same

household as you for at least one year;

or

d. legal person, trust or partnership:

• the managerial responsibilities of

which are discharged by you or by any

person referred to in (a) - (c) above;

• which is directly or indirectly

controlled by such a person;


https://marketoversight.fca.org.uk/electronicsubmissionsystem/MaPo_PDMR_Introduction




1312


• which is set up for the benefit of such

a person; or

• the economic interests of which are

substantially equivalent to those of

such a person.

If you are unsure whether a person or entity

might be considered to be a PCA, please

contact Company Secretary.

The FSA has stated that the last category

of connected persons will only include

companies of which you (or your connected

persons) are a sole director or where you

(or your connected persons) personally

have the power to control the company’s

management decisions affecting its future

development and business prospects, rather

than merely being able to exert influence.

Consequently, if you are on the Board of

Directors of another listed company, for

example, that listed company will not be one

of your connected persons.

Please fill in the PCA Questionnaire attached

at Attachment 3 of this letter with details of

your PCAs and email the list to Company

Secretary as soon as possible.

Share Dealing Code

The Company’s Share Dealing Code outlines

the obligation on you to seek clearance

before you deal in any securities of the

Company and to refrain from dealing in

certain periods.

In particular, you should seek to prohibit

your PCAs from dealing in closed periods

or on considerations of a short term nature.

You must also advise your PCAs of the fact

that you are a person discharging managerial

responsibilities at the Company, of the

closed periods during which they cannot

deal in the securities of the Company

and that they must advise the Company

immediately after they have dealt in the

Company’s securities.

Yours sincerely

…………………………………….……….……….

For and on behalf of Lamprell plc

Approved by:

Alex Ridout

Group General Counsel & Company

Secretary



1514


APPENDIX 2

Letter to permanent insiders


CONFIDENTIAL – ADDRESSEE ONLY

Permanent Insider List

This is to inform you that you have been

designated a Permanent Insider by the

Company’s Disclosure Committee and are

subject to the Company’s Share Dealing

Code. The Share Dealing Code can be found

at [ ].

As you will see from the Share Dealing

Code, Permanent Insiders must first obtain

approval from [the Chief Executive/Chairman

– amend according to role of the Permanent

Insider] or a designated director before

dealing in the Company’s shares. Save in

exceptional circumstances, clearance to deal

will only be given if no inside information

relating to the Company is in existence and

the Company is not in a ‘closed period’. If

you wish to deal in shares of the Company,

you should apply for clearance on the Form

entitled ‘Request for Authorisation to Deal

in Securities of Lamprell plc’. You should

also familiarise yourself with the Company’s

Disclosure Policy and Insider Dealing and

Market Abuse Policy.

Please ensure that all inside information

to which you have access is treated as

confidential and not conveyed by you to any

third party except where:

(i) the express consent of the Disclosure

Committee has been obtained; or

(ii) the Disclosure Committee has

determined that the Company is

permitted to delay public disclosure

of the inside information and the

disclosure is to an adviser of the

Company and is for a legitimate

purpose and such adviser is bound by

appropriate duties or obligations of

confidentiality to the Company.

You should not pass any inside information

to any other employees of the Company

other than those who require it to perform

their role.

You have been designated a Permanent

Insider and been placed on the Permanent

Insider List due to the nature of your role

in the Company and the fact that you

regularly or occasionally have access to the

Company’s inside information. If you move

roles or resign from your employment or

office please inform the Company Secretary.

If you require clarification on this note,

please contact the Company Secretary.

Please sign and return the enclosed copy

of this letter to the Company Secretary to

acknowledge your agreement to comply

with the terms of this letter.

………………………………………………………

For and on behalf of Lamprell plc

Date:

Letter to project insiders


CONFIDENTIAL – ADDRESSEE ONLY

Project Insider List

As you are aware, you are a member of the

team of Project [ ] (the Project). The

existence of the Project, and of information

generated from time to time from it, may

constitute inside information. Consequently,

you have been designated a Project Insider

and are subject to the Share Dealing Code

of Lamprell plc’s (the Company). The Share

Dealing Code can be found at [∞].

As you will see from the Share Dealing Code,

Project Insiders must first obtain approval

from [the Company Secretary – amend

according to the role of the Project Insider]

or a designated director before dealing in

the Company’s shares. Save in exceptional

circumstances, clearance to deal will only be

given if no inside information relating to the

Company is in existence and the Company is

not in a ‘closed period’. If you wish to deal

in shares of the Company you should apply

for clearance on the Form entitled ‘Request

for Authorisation to Deal in Securities of

Lamprell plc’. You should also familiarise

yourself with the Company’s Disclosure

Policy and Insider Dealing and Market Abuse

Policy.

Please ensure that the details and

existence of the Project and all other inside

information to which you have access is

treated as confidential and not conveyed by

you to any third party except where:

(i) the express consent of your Project

Leader or the Disclosure Committee

has been obtained; or

(ii) the Project Leader has designated

that third party as a member of the

Project team who requires the inside

information to perform his/her role; or

(iii) the Disclosure Committee has

determined that the Company

is permitted to delay the public

disclosure of the inside information

and, with the express consent of your

Project Leader, the disclosure is to an

adviser of the Company and is for a

legitimate purpose and such adviser

is bound by appropriate duties or

obligations of confidentiality to the

Company.

You should not pass any inside information

to any other employees of the Company

other than those who require it to perform

their duties and are a member of your

Project team.

If you leave the team working on the Project

or resign from your employment or office

please inform your Project Leader.

If you require clarification on this note,

please contact the Company Secretary.

I will write to you again in due course to let

you know when you are no longer subject to

the dealing Code.

Please sign and return the enclosed copy

of this letter to the Company Secretary to

acknowledge your agreement to comply

with the terms of this letter.

………………………………………………………For and on behalf of Lamprell plc

Date:



1716


TEMPLATE

REQUEST FOR AUTHORISATION TO DEAL IN SECURITIES OF

LAMPRELL PLC (the Company)

Request from:

Request to:

I request authority to deal in Lamprell plc ordinary shares as follows:

Transaction Details:

Description of securities:

Number of securities:

Nature of the dealing:

Other details:

Name:

Location:

Contact details:

My position in the Company:

My department:

Chairman/Chief Executive/Company Secretary (please delete as

appropriate *)

[e.g. a share, a debt instrument, a derivative or a financial

instrument linked to a share or debt instrument.]

[If actual number is not known, provide a maximum amount (e.g.

‘up to 100 shares’ or ‘up to £1,000 of shares’).]

[Description of the transaction type (e.g. acquisition; disposal;

subscription; option exercise; settling a contract for difference;

entry into, or amendment or cancellation of, an investment

programme or trading plan).]

[Please include all other relevant details which might reasonably

assist the person considering your application for clearance (e.g.

transfer will be for no consideration).]

[If you are applying for clearance to enter into, amend or cancel

an investment programme or trading plan, please provide full

details of the relevant programme or plan or attach a copy of its

terms.]

*Note (i) Employees should apply to the Company Secretary; (ii) the Chairman should apply to the Chief Executive (or, if not present, the Senior Independent Director, Board Committee or other nominated Director) (iii) the Chief Executive should apply to the Chairman (or, if not present, the Senior Independent Director

I confirm that the information I have provided is accurate and understand that the Company

is relying on the accuracy of such information in considering my request for authorisation to

deal. I also understand that the Company will consider my request and its obligations under the

Market Abuse Regulation and will respond as soon as reasonably practicable within a period of 5

business days of the request being made.

My immediate manager:

Your signature: Date:

Authorisation to deal given/not given by:

Name: Signature:

Title: Date:

I confirm that: Please tick

a. I have read and understood the Share Dealing Code which is available at [∞].

b. I am not and will not in breach of the Share Dealing Code in relation to this transaction

This authority is valid for TWO WORKING DAYS excluding the date of authorisation. If you

do not deal within the two day period you will need to get a new authority to deal.

If you are a Director or a Person Discharging Managerial Responsibilities or a Person

Closely Associated with a Director or a Person Discharging Managerial Responsibilities,

please supply to the Company Secretarial department, without delay following the

transaction, a completed copy of the Form entitled ‘Notification of Transaction by a PDMR

or Person Closely Associated with a PDMR’.



1918


NOTIFICATION FORM OF DEALINGS IN SECURITIES OF

LAMPRELL PLC (the Company)

Notification to:

Description of the financial instrument

Nature of the transaction

Details of PDMR/PCA: Name:

[Include first name(s) and last name(s).]

[If the PCA is a legal person, state its full name including legal

form as provided for in the register where it is incorporated, if

applicable.]

Position/Status:

[For PDMRs, state job title e.g. CEO, CFO.]

[For PCAs, state that the notification concerns a PCA and the

name and position of the relevant PDMR.]

Initial notification/amendment:

[Please indicate if this is an initial notification or an amendment

to a prior notification. If this is an amendment, please explain the

previous error which this amendment has corrected.]

Chairman/Chief Executive/Company Secretary (please delete as

appropriate *)

[e.g. a share, a debt instrument, a derivative or a financial instrument linked to a share or debt instrument.]

[Description of the transaction type e.g. acquisition, disposal, subscription, contract for difference, etc.][Please indicate whether the transaction is linked to the exercise of a share option programme.][If the transaction was conducted pursuant to an investment programme or a trading plan, please indicate that fact and provide the date on which the relevant investment programme or trading plan was entered into.]

:

:

Details of the transaction(s):

section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each

date; and (iv) each place where transactions have been conducted

*Note (i) Employees should apply to the Company Secretary; (ii) the Chairman should apply to the Chief Executive (or, if not present, the Senior Independent Director, Board Committee or other nominated Director) (iii) the Chief Executive should apply to the Chairman (or, if not present, the Senior Independent Director

Aggregated information [Please aggregate the volumes of multiple transactions when these transactions:

• relate to the same financial instrument;

• are of the same nature;

• are executed on the same day; and

• are executed at the same place of transaction.] [Please state the

metric for quantity.]

[Please provide:

• in the case of a single transaction, the price of the single transaction;

and

• in the case where the volumes of multiple transactions are

aggregated, the weighted average price of the aggregated

transactions.]

[Please state the currency.]

:

Date of transaction [Date of the particular day of execution of the notified transaction, using the date format: YYYY-MM-DD and please specify the time zone.]

:

Place of transaction [Please name the trading venue where the transaction was executed. If the transaction was not executed on any trading venue, please state ‘outside a trading venue’ in this box.]

:

Price(s) and Volume(s)

[Where more than one transaction of the same nature (purchase, disposal, etc.) of the same financial instrument are executed on the same day and at the same place of transaction, prices and volumes of these transactions should be separately identified in the table above, using as many lines as needed. Do not aggregate or net off transactions.]

[In each case, please specify the currency and the metric for quantity.]

Price(s) Volume(s):TEMPLATE



2120


I confirm that the information I have provided is accurate and understand that the Company

is relying on the accuracy of such information in considering my request for authorisation to

deal. I also understand that the Company will consider my request and its obligations under

the Market Abuse Regulation and will respond as soon as reasonably practicable within a

period of 5 business days of the request being made.

Your signature: Date:

This authority is valid for TWO WORKING DAYS excluding the date of authorisation. If you

do not deal within the two day period you will need to get a new authority to deal.

If you are a Director or a Person Discharging Managerial Responsibilities or a Person

Closely Associated with a Director or a Person Discharging Managerial Responsibilities,

please supply to the Company Secretarial department, without delay following the

transaction, a completed copy of the Form entitled ‘Notification of Transaction by a PDMR

or Person Closely Associated with a PDMR’.


Hamriyah Free Zone, Sharjah

P.O. Box 42149, Sharjah

United Arab Emirates

T: +971 6 528 2323

F: +971 6 528 4325

This document is in the custody of the

Group General Counsel & Company

Secretary

Copyright © Lamprell Energy Ltd. 2021




revision 5 september 221 lamprell share dealing code

Documents