BUBS AUSTRALIA LIMITED — Director's Dealing 2014

Jan 16, 2014

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16 January 2014

Ms J Hewitt Senior Adviser, Issuers Compliance (Perth) ASX Compliance Pty Ltd 2 The Esplanade PERTH WA 6000

BY EMAIL jill.hewitt@asx.com.au

Dear Ms Hewitt,

We refer to your letter dated 16 January 2014 and respond to your questions raised therein as follows.

1. Please explain why the Appendix was lodged late.

Mr Middleton informs us that he was on holidays between 3 January 2014 and 14 January 2014 and that during that period he was unaware that he had purchased shares in the Company on 3 January 2014. Upon his return from holidays, he was informed of the transaction and he then promptly informed the Company of the details of the transaction and the Appendix 3Y was lodged.

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?

The Company’s policy is that its directors must provide details of all share transactions to the Company Secretary within 48 hours of such transactions being effected.

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?

The Company believes that its current arrangements are adequate to ensure compliance with listing rule 3.19B.

Please let us know if you have any queries in relation to the above.

Yours sincerely, HILLCREST LITIGATION SERVICES LIMITED

Ian Allen

IAN ALLEN

Company Secretary.

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ASX Compliance Pty Limited ABN 26 087 780 489 Level 8 Exchange Plaza 2 The Esplanade PERTH WA 6000

GPO Box D187 PERTH WA 6840

Telephone 61 8 9224 0000 Facsimile 61 8 9221 2020 www.asx.com.au

16 January 2014

Mr I Allen Company Secretary Hillcrest Litigation Services Limited 1 Colin Street WEST PERTH WA 6005

Email: I A@hillcrestlitigation.com.au

Dear Ian

Hillcrest Litigation Services Limited (the “Company ”)– Director’s Interest Notice

We refer to the following;

1. The Appendix 3Y lodged by the Company with ASX on 15 January 2014.

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

3. 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 1 January 2002.

   • 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 1 January 2002 or the entity’s admission or a director’s appointment.

4. 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.

5. 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.

6. 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

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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.

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.

As the Appendix indicated that the changes occurred on 3 January 2014, it appears that the Appendix should have been lodged with the ASX prior to the close of business on 10 January 2014. As the Appendix was lodged on 15 January 2014, it appears that the Company may be in breach of listing rules 3.19A and/or 3.19B.

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 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. 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 e-mail at jill.hewitt@asx.com.au or by facsimile on facsimile number (08) 9221 2020. It should not be sent to the Market 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 (ie before 6.30 am. W.S.T.) on Monday 20 January 2014.

If you have any queries or concerns, please contact me immediately.

Yours sincerely,

[Sent electronically without signature]

Jill Hewitt Senior Adviser, Issuers Compliance (Perth)

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