OBJECTIVE CORPORATION LIMITED — Governance Information 2011

Jan 5, 2011

Objective

TRADING IN THE SHARES OF OBJECTIVE CORPORATION LIMITED ("OBJECTIVE")

ORGANISATION COMMITMENT

At Objective one of our core values is integrity and the Company expects our Directors and employees to demonstrate this when dealing with our Company's securities.

ELIGIBILITY

This policy applies to all employees and in all locations. Additional restrictions apply to our Directors and certain employees as noted below.

POLICY GUIDELINES

This policy provides the summary of insider trading restrictions and the procedure to be followed when dealing with the Company's shares or securities in other companies.

The Corporations Act prohibits the buying or selling of shares (or other securities) based on "Inside Information" (information not generally known to the market and, if known publicly, would likely have a material impact on the price of shares). It also prohibits Directors and Executives from using information gained in their capacity for their own advantage. In addition, as Objective is a listed company, the ASX requires Directors to inform the market of any changes in their interest in Company securities within five business days.

The laws governing the ability of 'Insiders' to buy and sell securities are called 'insider trading rules' and a breach of these rules can be a crime that can be the subject of a prison sentence. Basically no-one is allowed to buy or sell securities when they have material, price sensitive information not known to the investing 'public'.

POLICY REGARDING BUYING AND SELLING OBJECTIVE SHARES

The Company acknowledges that from time to time, Directors and members of Management and Staff may in the course of their duties become aware of Inside Information in respect of the Company.

The Company also acknowledges that from time to time, Directors and members of Management and Staff may in the course of their duties become aware of Inside Information in respect of other companies that the Company may be negotiating with.

1. Insider Trading (all Employees and all Directors)

The Company requires Directors, Management and Staff not to buy or sell the Company's shares (or other securities) at any point in time where the person involved has knowledge which constitutes Inside Information. This requirement also includes a restriction not to trade in other company securities where Inside Information has been obtained in relation to negotiations that the Company may be involved in.

1. Additional Restriction for Directors & Certain Employees (designated Employees only)

Additional restrictions apply to the Directors and certain employees - "Designated Officers".

© 1994-2010 Objective Corporation Ltd. All rights reserved.

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Objective

The Designated Officers are:

• Objective Directors (including Executive Directors)
• The Chief Executive Officer (CEO)
• The Executive Team
• Employees specifically notified by the Chief Financial Officer (CFO) or their Executive Team Member

2.1 Designated Officers are NOT permitted to buy or sell shares in the Company other than in exceptional circumstances approved by the Board during the period commencing 15 days prior to the last day of the half year or full year as the case may be and ending 24 hours after the release of the corresponding results announcement.

2.2 Designated Officers are permitted to buy or sell shares in the Company at any other time so long as they:

2.2.1 are not in possession of “Inside Information” (as the insider trading prohibitions continue to apply at all times); AND
2.2.2 follow the Notification Requirements set out in point 3 below.

2.3 Short term buying and selling of shares in the Company should be avoided where possible. Designated officers are not permitted to buy and sell shares in the Company within any 3 month period unless approval is provided by the Company.

3. Notification Requirements - Designated Officers Only

3.1 Where a Designated Officer intends to buy or sell shares in the Company, that person is required first to notify the CFO and the Company Secretary.
3.2 Where the person is either the CFO or Company Secretary then the notification must also be to the CEO.
3.3 All notifications must be in writing (includes email).
3.4 No prior notification is required for participation in any Company share or option plans or actions open to all shareholders.

The officers of Objective to whom the intention to buy or sell shares must first be notified are not authorised to prevent persons from trading, but will provide guidance as to whether or not, in their opinion, the person should trade at that particular time. The Company (via the Company Secretary) requires subsequent confirmation of the trading that has occurred.

Should a staff member choose to ignore the above guidance, then they may have to show cause to the Chief Executive Officer or the Board of Directors.

Directors and all employees are reminded that it is inappropriate to procure others to buy or sell shares in the Company (e.g. friends, associates) when the Director/employee is precluded from buying or selling, and are also reminded of the need to enforce confidentiality against external advisers.

4. Loan Security, Margin Loans & Share Lending Arrangements – Designated Employees

A Designated Officer is prohibited from using the Company’s shares:

4.1 as security in any loan arrangement where the shares or rights to shares have yet to vest or be issued to you under the offer document of any share or option incentive plan of the Company.

© 1994-2010 Objective Corporation Ltd. All rights reserved.

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Objective

4.2 in any margin loan unless prior approval is provided by the Board of Directors or approval of CEO.

4.3 to engage in any share lending arrangements, unless prior approval is provided by the Board of Directors.

1. Share Plans – Hedging – Designated Employees Only

A Designated Officer who is a participant under a Company share or option incentive plan is prohibited from entering into any transaction which operates to hedge the exposure of shares or share rights that are unvested or have yet to be issued by the plan manager under any share or option incentive plan, unless prior approval is provided by the Board of Directors.

STATUS OF THIS POLICY

The Company reserves the right to alter any of its terms at any time, although we will notify you in writing of any changes.

© 1994-2010 Objective Corporation Ltd. All rights reserved.