11. CONTINUOUS DISCLOSURE & SHAREHOLDER COMMUNICATION acknowledgment from the Chairman or his representative (and executives from the Secretary or a person appointed by the Board) of an intention prior to any dealings in securities either by themselves or by their associates, and must promptly notify details following the dealing.  The Company’s policy is that trading in Santos securities is permitted, with approval as set out above, only during the following periods:  Under the guidelines, prohibitions on dealing in securities apply not only to  the acquisition and disposal of shares, but also to the acquiring, taking, assigning and releasing of options traded in the options market. Directors and executives may not deal in securities on considerations of a short-term nature. The Company is committed to giving all shareholders timely and equal access to information concerning the Company. The Company has developed policies and procedures in accordance with its commitment to fulfilling its obligations to shareholders and the broader market for continuous disclosure. The policies are summarised in this Statement, which may be accessed at the Company’s website at www.santos.com.  The Company is currently in the process of compiling stand-alone summaries of relevant policies for inclusion on the Corporate Governance section of the Company’s website. The policies are regularly reviewed and updated for changes to the law and the Listing Rules. The Company notes that the ASX Best Practice Recommendations are for full copies of certain policies and charters to be included on the website. The Company has been working on this during the year, together with the update of the website itself. These will shortly be available on the Corporate Governance section of the website. These policies establish procedures to ensure that Directors and management are aware of and fulfil their obligations in relation to the timely disclosure of material price sensitive information. Information must not be selectively disclosed prior to being announced to the ASX, NASDAQ or New Zealand Exchange Ltd (NZX). Directors and executive management must notify the Company Secretary as soon as they become aware of information that should be considered for release to the market. When the Company makes an announcement to the market, that announcement is released to each exchange where its shares are listed: ASX, NASDAQ and NZX. The Company Secretary is responsible for communications with the exchanges. All material information disclosed to the ASX is posted on the Company’s website at www.santos.com. This includes ASX announcements, annual reports (including therefore this Corporate Governance Statement), notices of meeting, CEO briefings, media releases, and materials presented at investor, media and analyst briefings. An email “alert” facility is also offered to shareholders. Web-casting of material presentations, including annual and half-yearly results presentations, is provided for  the benefit of shareholders, regardless of their location.  Additionally, the Company’s external auditor attends annual general meetings to be available to answer shareholder questions relevant to the conduct of  the audit. • the period commencing  two clear days after the announcement of the Company’s annual results  and ending 1 July; and • the period commencing  two clear days after the announcement of the Company’s half yearly  results and ending 1 January. 34 Annual Report 2004