The following definitions are referred to within this Policy:

“Connected Persons” include:

1. the spouse or civil partner;

2. any children (including step-children) under 18 years of age;

3. a nominee, including an investment manager managing funds on their behalf;

4. a trust of which they, any member of their family, or any family controlled company, are the trustee or beneficiary;

5. a person in partnership with them or any of their connected persons mentioned in (a) to (c) above (acting in his or her capacity as such); or

6. a company which they or their family control.

“Deal” or “Dealing” includes:

1. any acquisition or disposal of, or agreement to acquire or dispose of the shares of the Company;

2. entering into a contract (including a contract for difference) the purpose of which is to secure a profit or avoid a loss by reference to fluctuations in the price of the shares of the Company;

3. the grant, acceptance, acquisition, disposal, exercise or discharge of any option to acquire or dispose of any of the shares of the Company;

4. entering into, or terminating, assigning or novating any stock lending agreement in respect of the shares of the Company;

5. using as security, or otherwise granting a charge, lien or other encumbrance over the shares of the Company;

6. any transaction, including a transfer for nil consideration, or the exercise of any power or discretion effecting a change of ownership of a beneficial interest in the shares of the Company; or

7. exercising any other right or fulfilling any obligation, present or future, conditional or unconditional, to acquire or dispose of any securities of the Company.

“Inside Information” is information of a nature which:

1. is not generally available to the general market; and

2. would, if generally available, be likely to have a significant effect on the price of Chellarams Plc’s shares.

“Employee Insiders” are Applicable Persons who are considered to have access to Inside Information on a regular or occasional basis and would automatically include:

1. all Directors of Chellarams Plc;

2. all Directors and Managers of Chellarams Plc’s Subsidiaries;

3. all Senior Executives of Chellarams Plc;

4. all Senior Executives of Chellarams Plc’s Subsidiaries;

5. certain members of the Finance division;

6. certain members of the Corporate Affairs division;

7. certain members of the Legal department;

8. certain members of the Information Technology department;

9. certain Personal Assistants; Executive Assistants/Administrative Assistants tot eh above roles;

10. any other person designated as an Employee Insider by any Director or Officer of Chellarams Plc, from time to time; and

11. acting as trustee: where a person to whom this policy applies acts as a trustee of a trust, this policy may also apply to dealings undertaken by that trust. Persons to whom this is relevant should seek further information from the Group Company Secretary/Legal Adviser.

If you are in doubt regarding whether you are classified as an Employee Insider, you must check with the Group Company Secretary/Legal Adviser. The Company Secretarial maintains a register of all Employee Insiders.

“Prohibited Period” is any Close Period or any period when there exists any matter which constitutes Insider Information in relation to Chellarams Plc.