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IMMUTEP LIMITED Director's Dealing 2009

Jul 2, 2009

65122_rns_2009-07-02_47128513-5ade-40b2-9e19-66c4816c2b70.pdf

Director's Dealing

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Friday 3rd July 2009

Alice Cope Senior Adviser, Issuers (Melbourne) Australian Securities Exchange Ltd (ASX) Level 45 South Tower 525 Collins St Melbourne VIC 3000

By Email

Dear Alice,

Prima Biomed Limited (the “Company”) – Change of Director’s Interest Notice

We refer to your letter dated the 2nd July 2009, whereby you have requested us to respond to your questions raised upon the late lodgement of an Appendix 3Y.

1. Please explain why the Appendices were lodged late.

These notices were not lodged on time due to an oversight by management.

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?

The Company has disclosure and reporting systems to monitor changes in Director’s Interests.

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 Secretary and Directors have been re-advised of disclosure obligations and will be prompted regularly to confirm their holdings are accurate, and if not accurate, to provide details of changes in their holdings.

Checklists have been put in place to ensure that due process is followed enabling timely and accurate disclosure of director’s interests.

For and on behalf of the Company,

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Robert Kleine Company Secretary Prima Biomed Limited

Prima BioMed Ltd , Suite 1, 1233 High St, Armadale, VIC 3143 Ph: +61 (0) 3 9824 5254 Fax: +61 (0) 9822 7735 www.primabiomed.com.au ABN: 90 009 237 889

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

GPO Box 1784 Melbourne VIC 3001

Telephone 61 3 9617 8656 Facsimile 61 3 9614 0303 www.asx.com.au

2 July 2009

Mr Robert Kleine Company Secretary Prima Biomed Limited Suite 1, 1233 High Street ARMADALE VIC 3143

By email only

Dear Phillip

Prima Biomed 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 on 30 June 2009 for Dr Richard Hammel.

  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.

  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.

  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.

As the Appendix 3Y indicates that a change in the director’s relevant interests occurred on 26 February 2009, it appears that the Director’s Notice should have been lodged with ASX by 5 March 2009. 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 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 Tuesday, 7 July 2009.

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

Alice Cope Adviser, Issuers (Melbourne)