Annual Report 200434
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: 
• 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.
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.
11. CONTINUOUS DISCLOSURE
& SHAREHOLDER
COMMUNICATION
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.
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