MINDAX LIMITED — Director's Dealing 2013

Jul 17, 2013

Level 2, 25 Richardson Street, West Perth WA 6005 PO Box 92, West Perth WA 6872 T +61 8 9485 2600 F +61 8 9485 2500 www.mindax.com.au ABN 28 106 866 442

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18 July 2013

Ms Elizabeth Harris Principal Adviser, Listings Compliance (Perth) ASX Compliance Pty Limited Level 8 Exchange Plaza 2 The Esplanade Perth WA 6000 By email: elizabeth.harris@asx.com.au

Dear Elizabeth

MINDAX LIMITED - CHANGE OF DIRECTOR’S INTEREST NOTICE

We refer to your correspondence of 17 July 2013 whereby you have requested Mindax Limited ( the Company ) respond to your questions raised upon the late lodgment of an Appendix 3Y for Mr Andrew Tsang.

The Company’s response is as follows:

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

The delay in providing the required information for the Appendix 3Y was caused by an administrative oversight on the director’s behalf, in that the director sought consent to purchase shares on the market (to ensure the Company was within an ‘open’ period, as required by the Company’s Dealing in Securities policy); however the director mistakenly did not pass on the details of the specific share transaction at the completion of the trade.

The notice was lodged once the oversight was identified.

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?

Formal arrangements are in place with each director of the Company as contemplated by ASX Listing Rule 3.19B and Guidance Note 22, whereby each director agrees and undertakes to provide the Company with details of any changes to their notifiable interests, within the time frames required by ASX Listing Rule 3.19A.

These reporting requirements are also enshrined in the Company’s aforementioned securities trading policy.

MINDAX LIMITED

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’s existing arrangements are considered adequate and the late lodgment of this particular Appendix 3Y notice was an isolated incident. In this regard, a subsequent share purchase by the same director was notified to the ASX within the required timeframe.

However, this issue will be raised at the next Board Meeting and the Company will re-state its arrangements with each director, including reminding directors of their responsibility to report all active changes, and monitor all non-active changes, in their notifiable interests.

Yours sincerely

MINDAX LIMITED

Christopher Pougnault Company Secretary

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ASX Compliance Pty Limited ABN 26 087 780 489 Level 8 Exchange Plaza 2 The Esplanade PERTH WA 6000 GPO Box D187 PERTH WA 6840

Telephone 61 8 9224 0000 Facsimile 61 8 9221 2020 www.asx.com.au

17 July 2013

Mr Christopher Pougnault Company Secretary Mindax Limited 25 Richardson Street WEST PERTH WA 6005

Dear Christopher

Mindax Limited (“Company”)

We refer to the following:

1. The Company’s announcement lodged with ASX Ltd (“ASX”) on 17 July 2013 regarding a change of director’s interest notice for Mr Andrew Tsang (“Appendix 3Y”);

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 an 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 an 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 an 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.

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.

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ASX Compliance Pty Limited ABN 26 087 780 489 Level 8 Exchange Plaza 2 The Esplanade PERTH WA 6000 GPO Box D187 PERTH WA 6840

Telephone 61 8 9224 0000 Facsimile 61 8 9221 2020 www.asx.com.au

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 listings rules 3.19A and 3.19B.

The Appendix 3Y indicates a change in Mr Andrew Tsang’s notifiable interest occurred on 5 July 2013 so the Appendix 3Y should have been lodged with the ASX by 12 July 2013. As the Appendix 3Y was lodged on 17 July 2013 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 Appendix 3Y 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 e-mail to Elizabeth.Harris@ASX.com.au or by facsimile on facsimile number (08) 9221 2020. 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 3:00PM WST on Friday 19 July 2013 .

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.

Yours sincerely

Elizabeth Harris rincipal Adviser, Listings Compliance (Perth)

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