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FBR LTD Director's Dealing 2008

Aug 13, 2008

64901_rns_2008-08-13_4683625c-8c5b-472e-b905-a307cf2ae23e.pdf

Director's Dealing

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Dromana Estate Limited

ABN 58 090 000 276

Registered Office: Level 6 412 Collins Street Melbourne Vic 3000 Tel (03) 9600 3242 Fax (03) 9600 3245 Winery/ Cellar Door Address: 555 Old Moorooduc Road, Tuerong Vic 3933 Tel (03) 5974 3899 Fax (03 5974 1155 Internet address: www.dromanaestate.com.au

13 August 2008

Ms Kate Kidson ASX Limited Level 45 Rialto South Tower 525 Collins Street Melbourne Vic 3000

By facsimile: (03) 9614 0303

Dear Ms Kidson

I refer to your letter dated 13 August 2008 and provide the following responses to the questions contained therein:

  1. The late lodgement of the appendices resulted from the late issue of chess statements following the distribution ‘in specie’ of Dromana Estate Ltd shares made by Authorised Investment Fund Limited, the unavailability of the Directors who were on annual leave and administrative oversight.

  2. The Directors have been provided with copies of Listing Ruling 3.19A and 3.19B and Guidance Note 22, together with a copy of Appendice 3Y and an instruction requesting all their future share transactions be notified to the company secretary promptly to ensure compliance with the Listing Rules.

  3. The current arrangements are considered to be adequate to ensure compliance with listing rule 3.19B at all times in the future.

Yours truly

Garry Bell

Company Secretary

Mr Garry Bell Company Secretary Dromana Estate Limited Level 6 412 Collins Street Melbourne VIC 3000

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ASX Limited ABN 98 008 624 691 Level 45 South Tower 525 Collins Street Melbourne VIC 3000

GPO Box 1784Q Melbourne VIC 3001 Telephone 61 (03) 9617 8831 Facsimile 61 (03) 9614 0303 Internet http://www.asx.com.au

13 August 2008

By e-mail only

Dear Garry

Dromana Estate Limited (the “Company”) Appendix 3Y – Change of Director’s Interest Notice

We refer to the following;

  1. The Appendices 3Y lodged by the Company with ASX on 6 August 2008 for Mr David Craig;

  2. The Appendix 3Y lodged by the Company with ASX on 6 August 2008 for Mr Geoffrey Bell;

  3. The Appendices 3Y lodged by the Company with ASX on 6 August 2008 for Mr Kenneth Russell;

  4. The Appendix 3Y lodged by the Company with ASX on 6 August 2008 for Mr Richard Green.

  5. Listing rule 3.19A 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.

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  1. 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.

  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 listing rules 3.19A and 3.19B.

The Appendices 3Y indicate that changes in the director’s relevant interests occurred on 9 July 2008; it appears that the Director’s Notices should have been lodged with ASX by 16 July 2008. 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 Appendices 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 return e-mail or by facsimile on facsimile number (03) 9614 0303. 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.S.T.) on Friday, 15 August 2008.

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 by electronic means without signature

Kate Kidson Principal Adviser, Issuers

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