FINBAR GROUP LIMITED — Director's Dealing 2011

Mar 15, 2011

16 March 2011

Mr Nicholas Ong Principal Advisor, Issuers (Perth) ASX Market Supervision Pty Ltd Level 8 Exchange Plaza 2 The Esplanade PERTH WA 6000

Dear Nicholas

RE: Appendix 3Y Directors Interest Notice - John Cheak

The Appendix 3Y was lodged with 24 hours of completion of an internal audit of Directors Shareholder Interests.

The Appendix 3Y was lodged late due to an oversight by the Company Secretary and a lack of communication between the Company Secretary and Mr John Cheak.

The Company has a written policy that details the Directors obligations to keep the Company informed of share transactions that could result in a change to their notifiable interests. The Directors are also reminded verbally on the occasions where the Company is aware of imminent notifiable events.

The Company has now introduced an audit process of reviewing on a weekly basis, through the share register of the Company, notifiable interest activities by all Directors.

Yours sincerely

‡dward Bank

Company Secretary

Level S. 15 Labouchere Ro SOUTH PERTH! Western Australia 6151

PO BOX 113 SOUTH FERTH Western Australia 6951 admin@finbar.com.aus

Telephone: +61 8 9474 4460 Facsimile: +61 8 9474 4458 www.finbar.com.au

16 March 2011

Mr Nicholas Ong Principal Advisor, Issuers (Perth) ASX Market Supervision Pty Ltd Level 8 Exchange Plaza 2 The Esplanade PERTH WA 6000

Dear Nicholas

RE: Appendix 3Y Directors Interest Notice - Loh Kee Kong

The Appendix 3Y was lodged with 24 hours of completion of an internal audit of Directors Shareholder Interests.

The Appendix 3Y was lodged late due to an oversight by the Company Secretary and a lack of communication between the Company Secretary and Mr Loh Kee Kong.

The Company has a written policy that details the Directors obligations to keep the Company informed of share transactions that could result in a change to their notifiable interests. The Directors are also reminded verbally on the occasions where the Company is aware of imminent notifiable events.

The Company has now introduced an audit process of reviewing on a weekly basis, through the share register of the Company, notifiable interest activities by all Directors.

Yours sincerely

Edward Bank Company Secretary

SOUTH PERTH Western Australia 6151

Level 3, 15 Labouchere Rd + PO Box 113 SOUTH PERTH. Western Australia 6951

edmin@finbarcom.au

Telephone: +61 8 9474 4460 Facsimile: +61 8 9474 4458 www.finbar.com.au

ASX Compliance Pty Ltd ABN 26 087 780 489 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

14 March 2011

Edward Bank Company Secretary Finbar Group Limited

By Email: ed@finbar.com.au

Dear Edward,

Finbar Group Limited (the "Company")

We refer to the following:

• 1. The Appendices 3Y lodged by the Company with ASX on 11 March 2011 for Mr Loh Kee Kong & Mr John Cheak (the "Appendices");
• 1. Listing rule 3.19A which requires an entity to tell ASX the following:
• The notifiable interests of a director of the entity (or in the case of a trust, a director 3.19A.1 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) 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.
• 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.

$\overline{4}$ 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 3.19_B

The Appendices 3Y indicate that a change in notifiable interest occurred on 4 February 2011. It appears that the Appendices should have been lodged with ASX by 11 February 2011. 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?
• 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?

Your response should be sent to me by e-mail at nicholas.ong@asx.com.au or by facsimile on facsimile number (08) 9221 2020. 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 7.30 a.m. W.S.T.) on Thursday, 17 March 2011.

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,

Delli

Nicholas Ong Principal Adviser, Listings (Perth)