Employees of Filtronic plc or its subsidiaries may from time to time become aware of information that could have an effect on the Company's share price (such as the award of a major new contract).

All employees are required, under the terms of their employment with the Company (or its subsidiaries) to keep all information relating to the Company confidential. Employees buying or selling shares in the Company whilst in possession of confidential information without the Company's consent would be guilty of misconduct which could result in disciplinary proceedings and even instant dismissal.

The Criminal Justice Act ("the CJA") makes it an offence for any employee in possession of Inside Information to buy or sell the Company's shares. The CJA also makes it an offence to encourage Insider Dealing* by others (e.g. a family member) or to disclose Inside Information with a view to that person profiting from it. Any person found guilty of an offence under the CJA can be punished by a fine or imprisonment.

Because the consequences of dealing in the Company's shares may be so serious for both employees and the Company, the Company has adopted a policy of requiring any employee to obtain clearance in writing from the Chairman or in his absence any executive Director of the Company before buying or selling shares in the Company. Requests for clearance to deal should in the first instance be directed to the Company Secretary.

In addition the Company has adopted the Stock Exchange's Model Code for transactions in securities by directors and employees ("The Code")

The Code requires employees, who because of their position within the Company are in possession of unpublished information that if published would result in a substantial movement in the price of the Company's shares, not to deal:

            -           on considerations of a short term nature; or

-           during a Close Period (being the 60 day period before the announcement of the Company's interim and annual results); or

            -           whilst in possession of unpublished price sensitive information; or

            -           without first notifying the Company Secretary and obtaining clearance to deal       from the Chairman of the Company or another designated director.

A breach of the code could result in the Company's listing on the Stock Exchange being suspended that could seriously affect the Company's ability to operate.

Dealing in shares by such an employee without clearance shall be regarded by the Company as serious misconduct that would normally result in instigation of disciplinary procedures that may involve dismissal.

June 2011

*Insider Dealing (Also known as insider trading) is generally, dealing in securities/shares on the basis of inside information, that is, information that is not yet publicly known and which would affect the price of the securities if it were made public. It is a criminal offence in the UK under the Criminal Justice Act 1993.

FILTRONIC
(which includes all companies in Filtronic group)
PANDEMIC FLU POLICY

Influenza is a highly infectious viral illness that has the capacity to spread rapidly. A pandemic is likely to occur when a new influenza strain emerges. It will spread rapidly because people will not have any natural resistance to it. It is difficult to predict the scale, severity and impact of a pandemic, but research suggests that it could affect the entire country and that up to half the population could develop the illness. There could also be more than one wave of the pandemic.

During a flu pandemic, Filtronic’s overall aim will be to encourage our staff to carry on as normal if they are well, while taking additional precautions to protect them from exposure to infection and to lessen the risk of spread to others.

In terms of business continuity, this means that we will seek to sustain our core business and services as far as is practicable during an influenza pandemic and therefore we will continue to operate largely within the existing framework of company policies and procedures. However the company recognises that during such times some additional provisions will be required to support staff.

DURING A PANDEMIC

During a recognised influenza pandemic, the company will implement the following provisions:

Communications:

During the period of a pandemic regular guidance and sources of information and support will be made available via line managers / supervisors, noticeboards, the company’s Intranet and Website. Staff should monitor these sources closely to stay up to date with what is happening within the workplace and what action is being taken to ensure the company meets it’s obligations to staff, customers and other stakeholders.

Additional Hygiene Arrangements:

• The company will provide antibacterial sanitiser located throughout company premises and staff will be encouraged and reminded to use these regularly.
• All surfaces, door handles, banister rails, telephones, computer keyboards etc. will be cleaned more frequently.
• All waste bins will be emptied daily.
• Staff are encouraged to always use clean tissues to cover their mouth / nose when they cough / sneeze (and not to use cloth handkerchiefs or re-use tissues) and to wash / sanitise their hands regularly.
Flu Vaccination
• The company may identify certain key staff and arrange for those staff to be given a flu vaccination at the company’s expense.
• This would be a purely voluntary arrangement and staff may refuse to have this if they wish.
Visitors
• Visitor passes will largely be discontinued except in exceptional circumstances for the duration of the pandemic.
• Visitors will be asked if they have any flu like symptoms before being allowed into company premises.
• Visitors will be asked to sanitise their hands before entering the company premises.

• Visitors will be accompanied and should be confined to meeting rooms where at all possible.
Face to Face Meetings
• Travel should largely be avoided unless absolutely essential and in particular if it involves the use of public transport.
• Face to face meetings should be avoided wherever possible and use of telephone / teleconferencing / email facilities should be encouraged.
• Where face to face meetings are unavoidable, the Company’s meeting rooms should be used which will have sanitiser pumps /tissues / waste bins provided and will be cleaned daily.
Staff Identified as Potentially At-risk
• Staff at risk of developing influenza-related complications (e.g. pregnant workers and those with compromised immune systems) will be reassigned from high-risk work sites and locations in the event of a pandemic. If this is not possible it may be necessary to ask such staff to work from home, or remain at home until it is deemed safe to return to the workplace.

Staff with Flu symptoms (the most significant symptoms are the sudden onset of:
fever, cough or shortness of breath; other symptoms may include: headache, tiredness, chills, aching muscles, sore throat, runny nose, sneezing, loss of appetite)

1. Whilst at Work
If a member of staff feels ill with symptoms consistent with flu, it is important that they do not simply carry on working. They should report their illness immediately to their line manager and if the symptoms are consistent with influenza, they will be sent home, advised to contact their GP and told not to return to work until the symptoms have cleared.
2. Whilst not at Work
If they develop symptoms whilst not at work, they should adhere to the following advice:
• Inform their line manager that they are ill using the recognised process
• Stay at home and rest
• Not go to work until they are fully recovered and their GP has confirmed they are no longer infectious
As part of the reporting procedures, the line manager will seek the permission of the employee to inform their colleagues that they are suffering from flu. This is really a private matter for the individual, but allowing colleagues to know about it will allow them to look out for early symptoms in themselves, and also allow any who may be at-risk in some way (e.g. pregnant) to seek medical advice.
Staff Who Have Difficulty Attending Work (where they themselves do not have flu)
In general staff will have no right to refuse to attend work during a pandemic unless there is a clear health and safety risk. Their employment contract will oblige them to carry out their normal duties and refusal to do so may put them in breach of their contract. However the company is aware that certain situations can occur:a) Public transport is shut down
Where an employee has difficulty getting to work because of a failure in the public transport system due to the pandemic, then they will be encouraged to seek other methods of getting to work. In exceptional circumstances it may be possible for some staff to work from home during this period of difficulty, to vary their start and end times, or to take annual or unpaid leave. Employees will not be paid if they fail to turn up for work and should discuss the options with their line manager as soon as possible.
b) The employee reports that a member of their household has been diagnosed with flu but that they themselves are OK and would be willing to attend work
The company recognises it has a duty of care to others in the workforce and the individual will be advised to remain at home until the ill relative is no longer infectious, however the company might wish to discuss the possibility of the employee working from home if possible. Under these circumstances the employee will receive their full pay as if they had been working normally.
c) The employee reports that their child or other dependant has flu and they are unable to arrange care at short-notice:
Under these circumstances the company recognises that the employee has a statutory right to a reasonable period of time off to care for these dependants. This is limited to sufficient time off to deal with the immediate issue and sort-out longer-term caring arrangements; the individual should discuss their situation with their line manager. The company will apply the provisions of its Special Leave Policy in these circumstances after which annual or unpaid leave would need to be taken. However if the sick individual is a member of the employees household then the provisions of b) above would apply.
d) The employee asks not to attend work because of fear of contracting flu:
The employee is contractually bound to attend work, and not doing so in these circumstances may be dealt with through the company disciplinary procedures. However if the company is convinced that the individual has psychological or physical reasons whereby they should not attend, then it may decide to agree to a period of annual / unpaid leave, or working from home arrangements with the employee concerned.
e) The employee has school-age children and the school is closed due to the influenza pandemic:

The provisions of c) above would apply
Working Flexibly
The impact of any pandemic will normally mean an increased workload due to a reduction in the actual staff available for work. It will therefore be essential that we maximise the capacity of our available workforce by asking staff to work more flexibly and /or differently. Therefore the company reserves the right to ask staff to undertake one or more of the following options:
• work additional hours to cover for sick colleagues
• work more flexibly as required
• work in a different job role for a period (with appropriate training)
• work from an alternative location, or even from home if appropriate
• cancel planned annual leave
The use of these flexible work practices will vary depending on the seriousness of the staff shortages and the needs of the business at that time. Staff will be paid based on the additional hours and responsibilities they undertake.Post Pandemic Considerations
After the first wave of a pandemic the company acknowledges that staff will need time to completely recover their full fitness and performance levels. Managers will ensure that staff who had been asked to work extended hours, or were denied their planned leave are given annual leave where at all possible. However the possibility of subsequent pandemic waves has to be kept in mind and the company will discuss with staff the lessons learnt from the current pandemic and continue with the preparations required to cope with subsequent waves.

Ref: MM:U: Risk Management
MM: U: Risk Management 2011: Group Policies 2011: July 2011 25 July v4 Clean

Hemant Mardia
      Chief Executive Officer, 
      Filtronic plc
      May 2010