First Graphene Ltd. — Director's Dealing 2011

Oct 11, 2011

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12 October 2011

The Manager Company Announcements Office ASX Limited Level 45, South Tower, Rialto 525 Collins Street MELBOURNE VIC 3000

Attention: Ms Kylie Barrie

Appendix 3Y – Directors Interest Notices

I refer to the above and your letter dated 10 October 2011 thereto.

In order of the questions raised in your letter, I notify you of the following:

1. the Appendix 3Y was lodged late as a result of an oversight by the Company Secretarial Department in not issuing these documents consequent on completion of the rights issue. The director supplied the necessary information to Robe in July 2011;

2. the arrangements that Robe has in place with its Directors to ensure that it is able to meet its disclosure obligations under listing rule 3.19A are as follows:

   • all Directors provide a declaration of their interests in Robe to the Company Secretarial Department on appointment and resignation; and

   • on receipt of such declarations the Company Secretarial Department issues an Appendix 3Y.

3. Robe considers that its current arrangements are adequate and being enforced to ensure compliance with listing rule 3.19B. The late lodgement was a result of an oversight by the Company Secretarial Department rather than inadequate arrangements being in place in relation to disclosure by the Directors required to enable issue of an Appendix 3Y.

Robe’s policies and procedures reflect its commitment to ensure full compliance with all listing rules. Unfortunately in this instance an administrative oversight has resulted in late lodgement. The importance of strict adherence to Robe’s policies and procedures has been reinforced to Company Secretarial Department staff.

Level 2, 409 St Kilda Rd, Melbourne Vic 3004. ABN 50 007 870 760. Telephone: (03) 9820 2322. Fax: (03) 9820 2158

Please contact me if you wish to discuss any of the above.

Yours faithfully,

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Peter Bolitho Company Secretary Robe Australia Limited

Level 2, 409 St Kilda Rd, Melbourne Vic 3004. ABN 50 007 870 760. Telephone: (03) 9820 2322. Fax: (03) 9820 2158

10 October 2011

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ASX Compliance Pty Ltd ABN 26 087 780 489 Level 45 Rialto South Tower 525 Collins Street Melbourne VIC 3000

GPO Box 1784 Melbourne VIC 3001

Peter Bolitho Company Secretary Robe Australia Limited Melbourne VIC 3004

Telephone 61 3 9617 8660 Facsimile 61 3 9614 0303 www.asx.com.au

By Email

Dear Peter

Robe Australia Limited (the “Company ”)

We refer to the following;

1. The Appendix 3Y lodged by the Company with ASX on 6 October 2011 for Mr Peter T Reilly;

2. 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) 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.

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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 a change in Peter T Reilly’s notifiable interest occurred on 26 July 2011. It appears that Mr Reilly’s notice should have been lodged with ASX by 2 August 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 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. 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 kylie.barrie@asx.com.au 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 (i.e. before 9.30 a.m. A.E.S.T.) on Thursday, 13 October 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

[Sent electronically without signature]

Kylie Barrie Adviser, Listings (Melbourne)