CYCLOPHARM LIMITED — Director's Dealing 2012

Nov 14, 2012

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cyclo medica molecular imaging techne gas

15 November 2012

Cyclopharm Ltd ABN 74 116 931 250 Bldg 75 Business & Technology Park New Illawarra Road Lucas Heights NSW 2234 Australia POB 350 Menai Central NSW 2234 T 61 2 9541 0411 F 61 2 9543 0960 www.cyclopharm.com.au

Ms Stephanie So Senior Adviser, Listings (Sydney) ASX Compliance Pty Limited 20 Bridge Street Sydney NSW 2000

Cyclopharm Limited (“Company”) Appendix 3Y – Change of Directors Interests

I refer to your letter dated 12 November 2012 and advise as follows:

1 . Please explain why the Notices were lodged late.

The Notices setting out the reduction in directors’ shareholdings arising from share consolidation and the lapsing of Long Term Incentive Shares were lodged late due to an oversight as the transactions had no financial impact which failed to trigger notification.

1. 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?

To ensure compliance with its disclosure requirements, the Company has in place a Continuous Disclosure and Market Communication Policy requiring all directors and staff to report to the Company all information required to be disclosed to the ASX. The directors are required to notify the Company of changes in their direct and indirect shareholdings as soon as they become aware of the transaction occurring. The directors have to date complied with this notification where shares have been traded on and off market.

1. 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 has updated its internal procedures in relation to the directors’ shareholdings disclosures to ensure that such an oversight will not occur again.

Yours faithfully Cyclopharm Limited

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James McBrayer

Managing Director and Company Secretary +612 9541 0411

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ASX Compliance Pty Limited ABN 26 087 780 489 20 Bridge Street Sydney NSW 2000 PO Box H224 Australia Square NSW 1215

12 November 2012

Telephone 61 2 9227 0125 Facsimile 61 2 9241 7620 www.asx.com.au

James McBrayer Managing Director Cyclopharm Limited Building 75 Business & Technology Park New Illawarra Road Lucas Heights NSW 2234

By Email

Dear James,

CYCLOPHARM LIMITED (the “Company”)

We refer to the following;

1. The Appendix 3Ys lodged by the Company with ASX on 6 November 2012 for James McBrayer;

2. The Appendix 3Y lodged by the Company with ASX on 6 November 2012 for Vanda Russell Gould;

3. The Appendix 3Y lodged by the Company with ASX on 6 November 2012 for David James Heaney;

(together, the “ Notices”);

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

2. 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. 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) including whether the change occurred during a closed period where prior written clearance was required and, if so, whether prior written clearance was provided. The entity must complete Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.

4. 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.

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1. Listing rule 3.19B which states as follows.

2. 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.

3. 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 Notices for the Directors indicate that changes in their notifiable interests occurred on 4 June 2012. In addition, the Notice for James McBrayer indicates that changes in his notifiable interests occurred on 3 June 2010, which have not been previously notified to the ASX by way of an Appendix 3Y. The Notices should have been lodged with ASX within 5 business days of change. Consequently, the Company may be in breach of listing rules 3.19A and/or 3.19B. It also appears the Directors 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 Notices were 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 e-mail 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 (ie before 9.30 a.m. A.E.D.T.) on Friday, 16 November 2012 .

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.

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Yours sincerely

[Sent electronically without signature] Stephanie So Senior Adviser, Listings (Sydney)