Immuron Ltd — Governance Information 2010

Dec 28, 2010

==> picture [188 x 40] intentionally omitted <==

==> picture [141 x 81] intentionally omitted <==

29 December 2010

The Manager The Company Announcement Office Australian Stock Exchange Sydney NSW 2000

Dear Sir Policy on Securities Trading

Attached is the Company’s Policy and Procedure on Securities Trading

==> picture [210 x 125] intentionally omitted <==

Graeme Stevens Company Secretary

1

IMMURON LIMITED ACN 063 114 045 (“Company”)

POLICY and PROCEDURE on SECURITIES TRADING

The Board of Immuron has established the following policy in respect of a designated officer , either directly or indirectly (including others acting on their behalf), dealing in the Company’s securities .

The overriding policy is that there are to be no dealings in the Company’s securities , whether in permitted periods or at any other time:

• a) when a designated officer is in possession of inside information , or

• b) where the dealing is for short-term or speculative gain, or

• c) within a period commencing 72 hours prior to and 72 hours after any announcement, or

• d) within a period commencing 72 hours prior to and 72 hours after the announcement of the half year and annual financial results.

A designated officer should not:

• a) communicate inside information or cause that information to be communicated to another person, and

• b) deal in the securities of outside companies about which they may gain inside information by virtue of their position at Immuron."

This Policy and the following Procedures are effective immediately.

Procedures

• a) The Managing Director will ensure that this Policy is brought to the attention of all designated officers .

• b) If any dealings are proposed, there should be prior consultation with the Chairman in the case of Directors, one of the non-executive Directors in the case of the Chairman, or the Managing Director in the case of employees and contractors.

• c) Written confirmation of any dealings is to be given to the person who approved the dealing. Such confirmation should;

  • include the date, description of the security, quantity and price,

  • be noted by the recipient, and

  • given to the Company Secretary for filing.

• d) Directors, pursuant to their agreement with the Company, must provide sufficient information within 3 working days to allow the Company to lodge Appendix 3Y. with the ASX.

• e) Designated officers should be aware of the need to enforce confidentiality against external advisors, contractors and their associates.

• f) The Audit & Risk Management Committee will periodically review compliance with this Policy and report any departures.

• g) This Policy is to be put on the Company's website and included in the annual report along with all other Corporate Governance policies.

1

Exclusions

The following forms of trading activity are excluded from the operation of the securities trading policy but remain subject to the insider trading provisions of the Corporations Act:

1. Excluded from this policy are s ecurities dealt with by an entity in which name the shares in the Company are registered and which the designated officer has a direct or indirect interest, but the designated officer is not in a position to influence the investment decisions of that entity;

2. transfers of securities which result in no beneficial ownership of the securities ;

3. transfers of securities already held in designated officer’s own name into a superannuation fund to which the designated officer is a beneficiary;

4. the acquisition, but not disposal, of securities offered under an employee share or option scheme;

5. acceptance of or agreement to accept a takeover offer; and

6. the acquisition of securities that arise from an offer made to all or most security holders, including a securities purchase plan, pro-rata rights issue, bonus issue, dividend re- investment plan and equal access buy-back.

Definitions.

"designated officer" includes Directors, key management employees, consultants, and their associates who may be in the possession of inside information.

"securities" include shares, options; financial products issued or created over the Company's securities by a third party and associated products which operate to limit the economic risk of their security holding in the Company.

"inside information" is information concerning any company's financial position, strategy or operations, which, if made public, would be likely to have a material impact on the price of the Company's securities.

General

This policy on securities trading encourages Directors and key management employees to be long term holders of the Company’s securities and discourages short term trading.

This policy will be reviewed regularly by the Board having regard to changing circumstances and any material changes to the policy will be promptly released to the ASX.

2