ORBMINCO LIMITED — Director's Dealing 2011

Jan 18, 2011

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18 January 2011

Jenny Cutri Assistant Manager, Listings Perth Australian Securities Exchange Via email: jenny.cutri@asx.com.au

Dear Jenny,

RESPONSE TO ASX QUERY - APPENDIX 3Y CHANGE OF DIRECTORS INTEREST NOTICE

I refer to your letter dated 14 January 2011 and provide responses below.

1. The Appendix 3Ys were lodged late due to an administrative error,

2. The Company has a Securities Trading Policy ("Policy") that was released to the ASX on 21 December 2010. The Policy outlines the process for notifying the Company of any changes in relation to holdings of securities by a Director, in order for the Company to meet its disclosure obligations under listing rule 3.19A.

3. The arrangements in place are adequate to enable compliance with listing rule 3.19B.

Sincerely,

Martin Stein Company Secretary Australian-American Mining Corporation Ltd

ASX Compliance Pty Limited ABN 26 087 780 489 2 Tho Esplanade Perth WA 6000

GPO Box D187 Perth WA 6840

Telephone 61 (08) 9224 0003 Facsimile 61 (08) 9221 2020 Internet http://www.asx.com.au

14 January 2011

Mr Martin Stein Company Secretary Australian-American Mining Corporation Limited Level 1 572 Hav Street PERTH WA 6000

By email: mstein@aspirecorporateconsultants.com

Dear Martin

Australian American Mining Corporation NL (the "Company")

We refer to the following:

• 1. Company's announcements lodged with ASX Ltd ("ASX") on 4 January 2011 regarding a change in the director's interest for Messrs James Malone, Denis Geldard, and Gregory Barns ("Appendix 3Ys").
• $\overline{2}$ . Listing rule 3.19A which requires an entity to tell ASX the following:
• The notifiable interests of a director of the entity (or in the case of a trust, a director of the 3.19A.1 responsible entity of the trust) at the following times.
  • On the date that the entity is admitted to the official list. $\sigma$
  • $\ddot{\mathbf{a}}$ 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.
• 1. 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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The Companies Update dated 27 June 2008, reminding listed entities of their obligation to notify ASX within 5 $\mathbf{4}$ 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 that a change in the Director's notifiable interest occurred on 17 December 2010. It appears that the Director's Notice should have been lodged with ASX by 24 December 2010. Consequently, the Company may be in broach of listing rules 3.19A and/or 3.19B. It also appears the directors concerned may have breached section 205G of the Corporations Act.

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.

• Please explain why the Appendix 3Ys were lodged late. 1.
• $\overline{2}$ . 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 at jonny.cutri@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 half an hour before the start of trading at 7.00am WST on Wednesday 19 January 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 must separately address each of the questions asked. If you have any queries or concerns, please contact me immediately.

Yours sincerely

Jenny Cutri Assistant Manager, Listings Perth)