INFOCUS GROUP HOLDINGS LIMITED — Director's Dealing 2016

Nov 17, 2016

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18 November 2016

Ms Hayley Pratt Adviser, Listing Compliance (Perth) ASX Compliance Pty Limited ( ASX ) Level 40, Central Park 152-158 St Georges Terrace Perth WA 6000

Dear Hayley,

RE: APPENDIX 3Y – CHANGE OF DIRECTOR’S INTEREST NOTICES

We refer to your letter dated 17 November 2016 in relation to the late lodgement of two Appendix 3Y forms and respond to the questions raised below.

1. Please explain why the Appendix was lodged late.

The delay in lodgement of the Appendix 3Y Notices was due to an internal administrative oversight. The notices were lodged immediately upon the oversight being identified. The Appendix 3Y’s relate to shares issued to directors upon conversion of Class A and Class B performance shares previously approved by shareholders a General Meeting of the Company.

2. What arrangements does the Entity have in place under listing rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under listing rule 3.19A?

Formal arrangements are in place with each director of the Company to ensure that the requirements of ASX Listing Rule 3.19A and 3.19B are met. The company secretary team has been counselled to ensure that in future, all securities are reported in a timely manner.

3. If the current arrangements are inadequate or not being enforced, what additional steps does the Entity intend to take to ensure compliance with listing rule 3.19B?

The Company considers that the current arrangements are adequate for ensuring timely notification, and that the failure to do so on this occasion was due to an oversight. However, to avoid a recurrence, the Company has its policy and procedures to ensure future compliance the ASX Listing Rules, specifically Listing Rule 3.19B.

Should you have any questions, please do not hesitate to contact me on (+61) 8 6489 1600.

Yours sincerely,

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Loren Jones Company Secretary

Wangle Technologies Limited info@wan.gl

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17 November 2016

Ms Loren Jones Suite 9 330 Churchill Avenue SUBIACO WA 6008

By email: loren@cicerocorporate.com.au

Dear Ms Jones

Wangle Technologies Limited (the “Company”)

We refer to the Company’s announcement lodged with ASX Ltd (“ASX”) on 12 November 2016 regarding a change in director’s interest notice for Keaton Wallace and Cameron Worth (amended version lodged with ASX on 15 November 2016 for Cameron Worth) (“Appendices 3Y”).

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.

Listing rule 3.19B which states as follows.

Level 40, Central Park www.asx.com.au 152-158 St George's Customer service 13 12 79 Terrace Perth WA 6000

ASX Compliance Pty Limited ABN 26 087 780 489

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.

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 Appendices 3Y indicate that a change in Keaton Wallace and Cameron Worth’s notifiable interests occurred on 3 November 2016 the Appendices 3Y should have been lodged with the ASX by 10 November 2016. As the Appendices 3Y was lodged on 12 November 2016 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 Appendices 3Y 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?

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 by e-mail to Wade.Baggott@asx.com.au. It should not be sent to ASX Market Announcements.

A response is requested as soon as possible and, in any event, not later than 3:00pm AWST Monday 21 November 2016.

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 must separately address each of the questions asked. If you have any queries or concerns, please contact me immediately.

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Yours sincerely,

[sent electronically without signature]

Hayley Pratt

Adviser, Listings Compliance (Perth)

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