POINTERRA LIMITED — Regulatory Filings 2008

Oct 30, 2008

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ASX Markets Supervision Pty Ltd ABN 26 087 780 489 20 Bridge Street Sydney NSW 2000 PO Box H224 Australia Square NSW 1215

29 October 2008

Telephone 61 2 9227 0602 Facsimile 61 2 9241 7620 www.asx.com.au

Graeme Scott Executive Chairman Soil Sub Technologies Limited Level 1 26 Clive Street West Perth WA 6005

Dear Graeme,

SOIL SUB TECHNOLOGIES LIMITED (the “Company”)

ASX Limited (“ASX”) refers to the following.

• 1.. The ASX Price Query letter dated 28 October 2008 (the “Query”) which noted an increase in the price of the Company’s securities from a low of $0.20 on 27 October 2008 to a high of $0.57 on 28 October 2008.

• The ASX Market Release dated 28 October 2008 regarding a halt in the trading of the Company’s securities, at the request of the Company and pending the release of an announcement by the Company.

• The following two announcements by the Company:

• 3.1 The announcement headed “Chinese Biodiesel Project Update” lodged with ASX on 28 October 2008, in which the Company provided an update on the biodiesel project under the licence agreement with Timms Cho Group Limited in China (the “Update”); and

• 3.2 The announcement headed “NutriMix Middle East Heads of Agreement Signed” lodged with ASX on 28 October 2008, regarding the signing of a Heads of Agreement (the “Transaction”) by the Company and a major organisation for the promotion and sale of NutriMix™ in the Middle East region (together, the “Announcements”).

• The Company’s response to the Query dated 28 October 2008 (the “Response”) in which the Company referred to the making of the Announcements, and stated that it did not believe either of the Announcements would have affected the price rise, or the increase in volume of securities traded on 27 October 2008.

As you are aware, listing rule 3.1 requires an entity, once it becomes aware of any information concerning it that a reasonable person would expect to have a material effect on the price or value of the entity’s securities, to immediately tell ASX that information. The exceptions to this requirement are set out in listing rule 3.1A.

I would also like to draw your attention to the definition of “aware” in Chapter 19 of the listing rules. This definition states that:

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“an entity becomes aware of information if a director or executive director (in the case of a trust, director or executive officer of the responsible entity or management company) has, or ought reasonably to have, come into possession of the information in the course of the performance of their duties as a director or executive officer of that entity”

Furthermore, paragraph 17 of Guidance Note 8 states:

“Once a director or executive officer becomes aware of information, he or she must immediately consider whether that information should be given to ASX. An entity cannot delay giving information to ASX pending formal sign-off or adoption by the board, for example.”

Listing rule 3.1A sets out an exception from the requirement to make immediate disclosure, provided that each of the following are satisfied.

• “3.1A.1 A reasonable person would not expect the information to be disclosed.

• 3.1A.2 The information is confidential and ASX has not formed the view that the information has ceased to be confidential.

• 3.1A.3 One or more of the following applies.

• It would be a breach of a law to disclose the information.

• The information concerns an incomplete proposal or negotiation.

• The information comprises matters of supposition or is insufficiently definite to warrant disclosure.

• The information is generated for the internal management purposes of the entity.

• The information is a trade secret.”

Finally, I would like to draw your attention to ASX’s policy position on the concept of “confidentiality” which is detailed in paragraphs 33 to 39 of Guidance Note 8. In particular, paragraphs 34 and 35 of the Guidance Note state that:

“‘Confidential’ in this context has the sense of ‘secret’…” and “Loss of confidentiality may be indicated by otherwise unexplained changes to the price of the entity’s securities, or by reference to the information in the media or analysts reports”.

Having regard to the above definition, listing rule 3.1, and Guidance Note 8 - Continuous Disclosure, we ask that you answer the following questions in a format suitable for release to the market in accordance with listing rule 18.7A.

1. Does the Company believe that the Announcements concerning the Update and the Transaction are material to the Company pursuant to listing rule 3.1?

2. If the answer to question 1 is “no”, please advise the basis on which the Company does not consider the Update and the Transaction to be material.

3. When did the Company first become aware of the Update and Transaction?

4. If this was before the Announcements, please identify any earlier announcement from the Company relating to the Update and the Transaction.

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1. If there was no earlier announcement, and the Company became aware of the Update and the Transaction prior to the Announcements, why was the information not released to the market at an earlier time? Please comment specifically on the application of listing rule 3.1 and the exception to the rule in listing rule 3.1A.

2. In addressing question 5 above, please consider whether the increase in the share price before the Announcement indicated that confidentiality in relation to the Update and Transaction had been lost.

3. Please confirm that the Company is in compliance with listing rule 3.1.

Your response should be sent to me by e-mail at stephanie.yong@asx.com.au or by facsimile on facsimile number (02) 9241 7620. It should not be sent to the Company Announcements Office.

Unless the information is required immediately under listing rule 3.1, a response is requested as soon as possible and, in any event, not later than the close of trading (ie before 4 p.m A.E.D.T.) on Friday, 31 October 2008.

If you are unable to respond by the time requested, you should consider a request for a trading halt in the Company’s securities. As set out in listing rule 17.1 and Guidance Note 16 - Trading Halts, we may grant a trading halt at your request. We may require the request to be in writing. We are not required to act on your request. You must tell each of the following.

• The reasons for the trading halt.

• How long you want the trading halt to last.

• The event you expect to happen that will end the trading halt.

• That you are not aware of any reason why the trading halt should not be granted.

• Any other information necessary to inform the market about the trading halt, or that we may ask for.

The trading halt cannot extend past the commencement of normal trading on the second day after the day on which it is granted. If a trading halt is requested and granted and you are still unable to reply to this letter before the commencement of trading, suspension from quotation would normally be imposed by us from the commencement of trading if not previously requested by you. The same applies if you have requested a trading halt because you are unable to release information to the market, and are still unable to do so before the commencement of trading.

If you have any queries regarding any of the above, please let me know.

Yours sincerely,

[sent electronically without signature]

Stephanie Yong Senior Adviser, Issuers (Sydney)

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