BIOTRON LIMITED — Director's Dealing 2009

May 3, 2009

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Level 2, 66 Hunter Street Sydney NSW 2000 Tel: (61-2) 9300 3344 Fax: (61-2) 9221 6333 E-mail: pnightingale@biotron.com.au Website: www.biotron.com.au

4 May 2009

ASX Markets Supervision Pty Ltd 20 Bridge Street Sydney NSW 2000

(3 pages by email)

Attention: Ms Lux Wigneswaran, Adviser, Issuers (Sydney)

Dear Lux

APPENDIX 3Y - CHANGE OF DIRECTOR'S INTEREST NOTICE

I refer to your letter dated 30 April 2009 and respond to your questions, using your numbering, as follows:

1. The Appendix 3Y was lodged late due to an administrative oversight.

2. The Company has communicated with all Directors advising them of their responsibility to disclose to the Company all the information required for the Company to complete Appendices 3X, 3Y and 3Z within the time period allowed by listing rule 3.19A. All Directors have provided written confirmation to the Company that they are aware of these responsibilities.

3. As most Directors of the Company were appointed more than 9 years ago, the Company will communicate with all Directors to remind them of their disclosure responsibilities and to have them reconfirm their understanding of their responsibilities.

Yours sincerely

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Peter J. Nightingale Company Secretary

pjn4760

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ASX Markets Supervision Pty Ltd ABN 26 087 780 489 20 Bridge Street Sydney NSW 2000 PO Box H224 Australia Square NSW 1215

Telephone 61 2 9227 0390 Facsimile 61 2 9241 7620 www.asx.com.au

30 April 2009

Mr Peter Nightingale Company Secretary Biotron Limited Level 2 66 Hunter Street Sydney NSW 2000

Dear Mr Nightingale,

Biotron Limited (the “Company ”)

Appendix 3Y – Change of Director’s Interest Notice

We refer to the following;

1. The Appendix 3Y lodged by the Company with ASX on 23 April 2009 for Mr Michael J. Hoy (the “Appendix 3Y”);

2. Listing rule 3.19A.2 which requires an entity to tell ASX the following:

   • 3.19A.1 The notifiable interests of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) at the following times.

     • On the date that the entity is admitted to the official list.

     • On the date that a director is appointed.

     • The entity must complete Appendix 3X and give it to ASX no more than 5 business days after the entity’s admission or a director’s appointment.

   • 3.19A.2 A change to a notifiable interest of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust). The entity must complete Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.

   • 3.19A.3 The notifiable interests of a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) at the date that the director ceases to be a director. The entity must complete Appendix 3Z and give it to ASX no more than 5 business days after the director ceases to be a director.

3. Listing rule 3.19B which states as follows.

An entity must make such arrangements as are necessary with a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) to ensure that the director discloses to the entity all the information required by the entity to give ASX completed Appendices 3X, 3Y and 3Z within the time period allowed by listing rule 3.19.A. The entity must enforce the arrangements with the director.

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1. The Companies Update dated 27 June 2008, reminding listed entities of their obligation to notify ASX within 5 business days of the notifiable interests in securities held by each director and outlining the action that ASX would take in relation to breaches of listings rules 3.19A and 3.19B.

The Appendix 3Y indicates that changes in Mr Hoy’s notifiable interests occurred on 21 December 2007 and 14 April 2009. It appears that corresponding Appendices 3Y should have been lodged with ASX by 2 January 2008 and 21 April 2009 respectively. Consequently, the Company may be in breach of listing rules 3.19A and/or 3.19B. It also appears the director concerned may have breached section 205G of the Corporations Act.

Please note that ASX is required to record details of breaches of the listing rules by listed companies for its reporting requirements.

ASX reminds the Company of its contract with ASX to comply with the listing rules. In the circumstances ASX considers that it is appropriate that the Company make necessary arrangements to ensure there is not a reoccurrence of a breach of the listing rules.

Having regard to listing rules 3.19A and 3.19B and Guidance Note 22: “Director Disclosure of Interests and Transactions in Securities - Obligations of Listed Entities”, we ask that you answer each of the following questions:

1. Please explain why the Appendix 3Y was lodged late.

2. What arrangements does the Company have in place with its directors to ensure that it is able to meet its disclosure obligations under listing rule 3.19A?

• 3 If the current arrangements are inadequate or not being enforced, what additional steps does the Company intend to take to ensure compliance with listing rule 3.19B?

Your response should be sent to me by email at luxmy.wigneswaran@asx.com.au or by facsimile on facsimile number (02) 9241 7620. It should not be sent to the Company Announcements Office.

A response is requested as soon as possible and, in any event, not later than half an hour before the start of trading (i.e. before 9.30 a.m. A.E.S.T.) on Monday, 4 May 2009.

Under listing rule 18.7A, a copy of this query and your response will be released to the market, so your response should be in a form suitable for release and should separately address each of the questions asked. If you have any queries or concerns, please contact me immediately.

Yours sincerely,

[sent electronically without signature]

Lux Wigneswaran

Adviser, Issuers (Sydney)