OLDFIELDS HOLDINGS LIMITED — Director's Dealing 2011

Jul 10, 2011

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OLDFIELDS HOLDINGS LIMITED

ACN: 000 307 988 PO BOX 1613, CAMPBELLTOWN NSW 2560 Telephone: 02 4627 0777 Facsimile: 02 46 27 0888

11 July 2011

Mr. Elvis Onyura ASX Compliance Pty Ltd 20 Bridge St Sydney NSW 2000

By Email

Dear Mr. Onyura

Appendix 3Y - Change of Director’s Interest Notice re your letter dated 6 July 2011

Having regards to listing rules 3.19A and 3.19B and Guidance Note 22 please see response below to each of your questions.

1. The Hext Notice was lodged late as there was an incorrect assumption that a notice was not required due to there being no net movement in security holdings.

2. To ensure that the Company is able to meet its disclosure obligations under listing rule 3.19A a complete revision of the said listing rule has been carried out and the Company now has a better understanding of the requirements.

3. The Company believes that the current arrangements are adequate and no additional steps are required to ensure compliance.

Yours sincerely,

Robert Allan Coleman Secretary

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ASX Compliance Pty Ltd ABN 26 087 780 489 20 Bridge Street Sydney NSW 2000 PO Box H224 Sydney NSW 1215 www.asx.com.au

6 July 2011

Mr. Robert Coleman Company Secretary Oldfields Holdings Limited 8 Farrow Road Campbelltown NSW 2560

By Email

Dear Mr. Coleman

Oldfields Holdings Limited (OLH) (the “Company ”) Appendix 3Y – Change of Director’s Interest Notice

We refer to the following;

1. The Appendix 3Y lodged by the Company with ASX on 5 July 2011 for Mr. Christopher Hext (the “Hext Notice”).

2. Listing rule 3.19A and in particular, listing rule 3.19.A.2 which requires an entity to tell ASX the following:

3. 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 Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.

4. 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.

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 Hext Notice indicates that a change in the Directors’ notifiable interest occurred on 3 June 2011. It appears that the Hext Notice should have been lodged with ASX by 10 June 2011. Consequently, the Company may be in breach of listing rules 3.19A and/or 3.19B. It also appears the director concerned may have breached section 205G of the Corporations Act in relation to the Hext Notice.

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 Hext Notice 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. 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 at elvis.onyura@asx.com.au or by facsimile on facsimile number (02) 9241 7620. 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 9.30 a.m. AEST on Monday, 11 July 2011 .

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 should separately address each of the questions asked. If you have any queries or concerns, please contact me immediately

Yours sincerely,

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Elvis Onyura Adviser, Listings (Sydney)

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