ION VIDEO LTD — Director's Dealing 2019

Jul 17, 2019

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LINIUS TECHNOLOGIES LIMITED

ACN 149 796 332

18 July 2019

Ms Jessica Coupe Adviser, Listings Compliance Australian Securities Exchange Level 40, Central Park, 152-158 St George's Terrace PERTH WA 6000

By email: jessica.coupe@asx.com.au

Dear Ms Coupe

LINIUS TECHNOLOGIES LIMITED APPENDIX 3Y – CHANGE OF DIRECTOR’S INTEREST NOTICE QUERY

We refer to your letter dated 16 July 2019 concerning the Appendix 3Y–Director’s Interest Notices that were lodged by Linius Technologies Limited (ASX:LNU) ( Company ) with ASX Limited on 12 July 2019 for Mr Stephen McGovern and Mr Christopher Richardson and respond as follows:

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

In each case the Appendix 3Y was lodged late due to an administrative oversight. Promptly upon becoming aware of this oversight, the document was prepared and lodged. The Company notes that the changes to the director interests related to the expiry of share options and not any purchase or disposal transaction of securities in the Company by either of Mr McGovern or Mr Richardson.

1. 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?

The Company and its directors are aware of their responsibilities under ASX Listing Rules 3.19A and 3.19B. Each director is made aware upon joining the Company’s board of directors of their respective obligations to the Company regarding detailing of any changes in their notifiable interests.

1. 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 believes that its current practices are adequate and ordinarily effective to ensure compliance with ASX Listing Rules 3.19A and 3.19B. The late lodgement of the Appendix 3Y in question was an unfortunate oversight on the part of the Company and does not reflect a deficiency in its internal procedures.

Yours faithfully

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Giuseppe Rinarelli Company Secretary

LINIUS TECHNOLOGIES LIMITED ACN 149 796 332 Suite 13, Level 3, 299 Toorak Road, South Yarra, Victoria, 3141 Tel +61 3 8672 7186 www.linius.com

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16 July 2019

Reference: ODIN04170

Mr Giuseppe Rinarelli Company Secretary Linius Technologies Limited Suite 0313, Level 3, 299 Toorak Road South Yarra VIC 3141

By email: jrinarelli@linius.com

Dear Mr Rinarelli

Linius Technologies Limited (‘LNU’): Appendix 3Y – Change of Director’s Interest Notice Query

ASX refers to the following:

1. LNU’s Appendix 3Y lodged on the ASX Market Announcements Platform (‘MAP’) on 12 July 2019 for Mr Christopher Richardson; and

2. LNU’s Appendix 3Y lodged on the ASX Market Announcements Platform (‘MAP’) on 12 July 2019 for Mr Stephen McGovern,

(together, the ‘Notices’).

1. 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.’

1. Listing rule 3.19B which states that:

‘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.’

ASX Customer Service Centre 131 279 | asx.com.au

ASX Limited [[Listings]]

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The Notices indicate that changes in Mr Richardson’s and Mr Govern’s notifiable interests occurred on 31 March 2019. It appears that the Notices should have been lodged with ASX by 5 April 2019. Consequently, LNU may have breached Listing Rules 3.19A and/or 3.19B. It also appears that Mr Richardson and Mr McGovern may have breached section 205G of the Corporations Act 2001 (Cth).

Please note that ASX is required to record details of breaches of the Listing Rules by listed entities for its reporting requirements.

ASX reminds LNU of its contract with ASX to comply with the Listing Rules. In the circumstances, LNU should make necessary arrangements to ensure it does not continue to breach the Listing Rules.

Request for Information

Under Listing Rule 18.7, we ask that you answer each of the following questions 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 .

1. Please explain why the Appendices 3Y were lodged late.

2. What arrangements does LNU 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?

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

When and where to send your response

Your response should be sent to me by e-mail at ListingsCompliancePerth@asx.com.au . It should not be sent to the ASX Market Announcements Office.

A response is requested as soon as possible and, in any event, no later than half an hour before the start of trading (i.e. before 9:30 am AEST) on 19 July 2019.

Under Listing Rule 18.7A, a copy of this letter 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.

Enquiries

If you have any queries or concerns about any of the above, please contact me immediately.

Yours sincerely

Jessica Coupe

Adviser, Listings Compliance (Perth)

2/2 ASX Customer Service Centre 131 279 | asx.com.au