GRANGE RESOURCES LIMITED. — Director's Dealing 2013

Oct 23, 2013

23 October 2013

Dale Allen Advisor, Listings Compliance (Perth) ASX Perth Level 8, Exchange Plaza 2 The Esplanade PERTH WA 6000

By email: Dale.allen@asx.com.au

Dear Dale

Re: APPENDIX 3Y QUERY

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I refer to your letter of 22 October 2013 regarding the Appendix 3Y lodged by the Company for Mr Cheung (Clement) Ko on 18 October 2013. The Company responds to the ASX’s questions as follows:

1. Please explain why the Appendix 3Y was lodged late?

The purchase of the shares was undertaken by a custodian on behalf of Mr Ko. It was an oversight on the part of Mr Ko to advise the Company of the purchase of these shares. The Company became aware of the shares following a recent change in Mr Ko’s custodian arrangements when the new custodian disclosed the shares as part of the beneficial owner analysis conducted by the Company. Upon becoming aware of this the Company then took immediate steps to contact Mr Ko to confirm the ownership of the shares and to organise the lodgement of Appendix 3Y.

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?

The Company has a Dealing in Securities Policy which details the procedures to be followed in the event that senior executives or Directors wish to buy or sell Company securities. A copy of the policy is on the Company’s website and is circulated to all staff and Directors at the start and conclusion of each trading black out period by the Company Secretary. Under the policy Directors are required to seek permission to trade and are required to advise the Company of any changes to their shareholding within two business days of the transaction. This allows time for the Company to prepare and lodge the required ASX Appendix within the required 5 day period.

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 does not consider that its current arrangements are inadequate and highlights its historical track record of compliance with Listing Rule 3.19A. In addition to the notification of the matter to the Audit Committee as required by the Policy, the Company will write to each Director and remind them of the requirements of Listing Rule 3.19A and the importance of compliance with it.

Yours faithfully

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Pauline Carr

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

22 October 2013

Ms Pauline Carr Company Secretary Grange Resources Limited PO Box 659 Burnie TAS 7320

By Email: Pauline.carr@grangeresources.com.au

Dear Pauline

Grange Resources Limited (the “Company”) Appendix 3Y – Change of Director’s Interest Notice.

We refer to the following;

1. The Appendix 3Y lodged by the Company with ASX Limited (“ASX”) on 18 October 2013 for Mr Cheung (Clement) Ko.

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). 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 listings rules 3.19A and 3.19B.

As the Appendix 3Y indicated that changes in the directors’ relevant interests occurred on 20 April 2013, it appears that the Appendix 3Y should have been lodged with the ASX by 29 April 2013. As the Appendix 3Y was lodged on 18 October 2013, 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 3Y 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 to dale.allen@asx.com.au or 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 (i.e. before 4.00pm W.S.T.) on Thursday 24 October 2013 .

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 ]

Dale Allen Adviser, Listings Compliance (Perth)

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