OBJECTIVE CORPORATION LIMITED — Director's Dealing 2019

Jan 7, 2019

Objective

Objective Corporation Limited

Lovel 30

177 Pacific Highway

North Sydney NSW 2060

Australia

Phone: +61 2 9955 2288

www.objective.com

Belinda Chiu

ASX Listing Compliance (Sydney)

Exchange Centre, 20 Bridge St

Sydney NSW 2000

4 January 2019

Dear Belinda

Appendix 3Z – Final Director’s Interest Notice Query

We refer to your letter dated 2 January 2019 and the request for information contained therein. Please see our responses below.

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 Appendix 3Z was lodged late.

Response: The announcement of Mr Warren’s resignation was released to the ASX on 28 November 2018. The Appendix 3Z was prepared and the information confirmed prior to that date. Due to an oversight, the pages containing the Appendix 3Z was not attached to the announcement lodged with the ASX. Once notified of the error, the Appendix 3Z was lodged immediately on 2 January 2019.

1. What arrangements does OCL 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?

Response: Directors are required to notify the Company Secretary and CEO of any changes in their relevant interest in Objective securities. This process is outlined in the “Trading in the Shares of Objective Policy” which is provided to Directors. The Company Secretary also monitors the share registry information to identify any changes and periodically requests directors to confirm the information held by the Company is correct.

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

Response: We believe the current arrangements to be sufficient and are being enforced.

Yours faithfully

Ben Tregoning

CFO/Company Secretary

On behalf of Objective Corporation Limited

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ASX

2 January 2019

Mr Ben Tregoning
Company Secretary
Objective Corporation Limited

By email:

Dear Mr Tregoning

Objective Corporation Limited ('OCL'): Appendix 3Z – Final Director’s Interest Notice Query

ASX refers to the following:

1. OCL’s Appendix 3Z lodged on MAP on 2 January 2019 for Mr Leigh Warren (the ‘Notice’);
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) 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.”

As the Appendix 3Z indicated that the director ceased to be a director on 28 November 2018 it appears the Appendix 3Z should have been lodged with ASX by 5 December 2018. As it was lodged on 2 January 2019, it appears that OCL may have breached 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 entities for its reporting requirements.

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

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

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

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 Appendix 3Z was lodged late.
2. What arrangements does OCL 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 OCL 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 ListingsComplianceSydney@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 AEDT) on 4 January 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.

Kind regards

Belinda Chiu
Senior Adviser, Listings Compliance (Sydney)