HITECH GROUP AUSTRALIA LIMITED — Director's Dealing 2011

Jan 9, 2011

HITECH GROUP AUSTRALIA LIMITED A.B.N. 41 062 067 878

TRADING POLICY FOR BUYING AND SELLING THE ENTITY’S SECURITIES

1. INTRODUCTION

These guidelines set out the policy on the sale and purchase of securities in HiTech Group Australia Limited (“Company”) by its Directors and key management personnel.

Directors of the Company (“Directors”) and key management personnel are encouraged to be long-term holders of the Company’s securities. However, it is important that care is taken in the timing of any purchase or sale of such securities.

2. GUIDELINES FOR TRADING IN THE COMPANY’S SECURITIES

2.1 General rule

The closed periods when Directors, key management personnel, consultants or contractors are not permitted to trade Company shares in the two (2) week period immediately prior to the release of and the three (3) business day period following the release of the Company's half yearly and annual results.

Directors and key management personnel are also not permitted to trade Company shares if in the possession of price-sensitive information at any time.

The Company may at its discretion vary this rule in relation to a particular period by announcement to all key management personnel either before or during the period.

However, if a Director or key management personnel of the Company is in possession of price- sensitive information which is not generally available to the market, then he or she must not deal in the Company’s securities at any time.

2.2 Trading in the Company’s securities in exceptional circumstances

In exceptional circumstances, where it is the only reasonable course available to a Director, a key management person, consultant or contractor, clearance may be given to sell (but not to purchase) HiTech Group securities when such HiTech Group personnel would otherwise be prohibited from doing so but not while there exists any matter which constitutes insider information in relation to HiTech Group securities. Such clearance may be obtained by following the steps set out in para 3.

2.3 No short-term trading in the Company’s securities

Directors, key management personnel, consultants or contractors should never engage in short-term trading of the Company’s securities except for the exercise of options.

2.4 Exceptions

• (a) Directors and all key management personnel may at any time:

  • (i) acquire ordinary shares in the Company by conversion of securities giving a right of conversion to ordinary shares;

• (ii) acquire Company securities under a bonus issue made to all holders of securities of the same class;

• (iii) acquire, or agree to acquire or exercise options under a Company Share Option Plan;

3. APPROVAL AND NOTIFICATION REQUIREMENTS

Any Director wishing to buy, sell or exercise rights in relation to the Company’s securities must obtain the prior approval of the Chairman or the Board before doing so.

If the Chairman wishes to buy, sell or exercise rights in relation to the Company’s securities the Chairman must obtain the prior approval of the Audit Committee Chairman before doing so.

All other key management personnel wishing to buy, sell or exercise rights in relation to the Company’s securities must obtain the Managing Director’s prior approval before doing so.

Personnel wishing to sell HiTech Group securities due to exceptional circumstances during a blackout period must obtain prior approval for the transaction by providing details of the exceptional circumstances and of the securities to be sold. The Chairman must obtain written consent from the Audit Committee Chairman and Directors, key management personnel, consultants and contractors from the Chairman.

4. ASX AND OTHER SECURITIES EXCHANGES NOTIFICATION FOR DIRECTORS

The ASX Listing Rules require the Company to notify the ASX within 5 business days after any dealing in securities of the Company (either personally or through an Associate) which results in a change in the relevant interests of a Director in the securities of the Company. The Company has made arrangements with each Director to ensure that the Director promptly discloses to the Company Secretary all the information required by the ASX.

5. EFFECT OF COMPLIANCE WITH THIS POLICY

Compliance with these Guidelines for trading in the Company’s securities does not absolve that individual from complying with the law, which must be the overriding consideration when trading in the Company’s securities.