L1 GROUP LIMITED — Governance Information 2011

Nov 15, 2011

Issue Date: 16 November 2011

PTM TRADING POLICY

A. APPLICATION

1. This Policy is authorised by the Board of Directors (the “Board”) of Platinum Asset Management Limited ABN 13 050 064 287 (the “Company”) and applies to:

   • Non-Executive and Executive Directors of the Company and its controlled entities (together the “Platinum Group”);

   • ‘associates’ of the Platinum Group, as defined by the Corporations Act 2001 (the “Act”);

   • staff of the Platinum Group - which includes permanent, part-time and casual employees and any contractors or consultants working at premises of the Platinum Group; and

   • ‘external members’ of the Platinum Trust Funds’ Compliance Committee;

collectively referred to (in this Policy) as “Platinum persons”.

1. This Policy also applies to a person or entity which is under the ‘control’ of a Platinum Person.

OBJECTIVE

B.

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D. TRADING RESTRICTIONS

1. Platinum persons are prohibited from trading in PTM Securities, and may not procure others to trade (including on their behalf), whilst aware of unpublished ‘price-sensitive information’ - i.e. information that a reasonable person would expect to have a material effect on the price or value of PTM Securities.

2. Platinum persons are prohibited from trading in PTM Securities and may not procure others to trade (including on their behalf) during the following periods:

   • from 1 January (each year) until the next business day after announcement of the half-yearly financial results of the Company to the ASX ( usually around mid-February each year );

   • from 1 July (each year) until the next business day after announcement of the annual financial results of the Company to the ASX ( usually around mid-August each year ); and

   • any other “black-out period” notified by the Company Secretary or the Chief Compliance & Risk Officer.

Each of the above is a “Closed Period”.

1. This Policy establishes when, and under what requirements, Platinum persons may buy or sell PTM shares or options issued by the Company.

2. This Policy forms part of the Platinum Group’s Compliance Framework and is aimed at preventing actual or perceived conflicts of interest and maintaining the reputation of the Platinum Group.

SCOPE

C.

This Policy applies to trading in PTM shares, options, and any other securities issued by the Company (from time to time), as well as trading in financial products (e.g. derivatives) that are issued or created over PTM shares by third parties, and trading in associated products (together “PTM Securities”).

1. Platinum persons are not permitted to actively trade in PTM Securities. PTM Securities are to be held for a minimum period of six months.

2. Platinum persons must comply with market prohibitions - references to the Act are provided in Section F.

3. Platinum persons are prohibited from entering into transactions in associated products which operate to limit the economic risk of holding PTM shares over unvested entitlements.

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Issue Date: 16 November 2011

PTM TRADING POLICY

E. MONTHLY TRADING WINDOW

1. Provided that Platinum persons are not aware of price-sensitive information, and other Trading Restrictions (in Section D) are not in effect, Platinum persons may buy or sell PTM Securities:

• from the next business day after announcement of the Company’s monthly funds under management figure to the ASX until the last trading day of the month;

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• false, misleading and dishonest conduct - s.1041E, s.1041F and s.1041G.

It is illegal for Platinum persons to carry out market conduct that is in direct contravention of these provisions.

QUESTIONS

G.

1. Any questions in relation to this Policy should be referred to the Company Secretary or the Chief Compliance & Risk Officer.

unless otherwise advised by the Company Secretary or Chief Compliance & Risk Officer.

2.

Trade Confirmation

Platinum persons must provide a trade confirmation to Compliance (as per Platinum’s Business Rules of Conduct).

3. No Exception

There are no circumstances in which Platinum Persons will be granted authority by the Company to trade PTM Securities during a Closed Period. The Board believes the Monthly Trading Window is sufficiently wide enough.

F. MARKET PROHIBITIONS

1. Insider Trading

Section 1043A of the Act prohibits ‘insider trading’.

2. Market Misconduct

The ‘market misconduct’ provisions of the Act prohibit certain trading behaviour and activity:

• market manipulation - s.1041A;

• false trading and market rigging - s.1041B and s.1041C;

• dissemination of information about illegal transactions - s.1041D; and

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