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SERVICE STREAM LIMITED — Director's Dealing 2011
Feb 13, 2011
65865_rns_2011-02-13_b737ca68-3b76-44d3-bdb1-b84de4ecee0b.pdf
Director's Dealing
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Service Stream Limited Level 1, 355 Spencer Street West Melbourne, VIC 3003 PO Box 14570, Melbourne, VIC 8001 www.servicestream.com.au
Tel: 61 3 9677 8888
Fax: 61 3 9677 8800 ABN: 46-072-369-870
14 February 2011
Mr Darren Collins Senior Advisor, Listings ASX Compliance Pty Ltd Level 45 Rialto South Tower 525 Collins Street MELBOURNE VIC 3000
By Email: [email protected]
Dear Mr Collins,
Service Stream Limited Re: Appendix 3X - Initial Director's Interest Notice
I refer to your letter dated 10 February 2011 and to my subsequent discussions with your office in relation to the Appendix 3X for Mr Robert Gerald Grant lodged by the Company with ASX on 4 February 2011 and respond to questions on page 2 of your letter as follows:
1. Please explain why the Appendix was lodged late.
The Company has procedures in place for the induction of Directors, which include the lodgement of Initial Director's Interest Notices upon their appointment.
As these induction procedures are most frequently applied in relation to the appointment of Non-Executive Directors, this obligation in relation to lodgement of Initial Director's Interest Notice was overlooked in relation to Mr Grant's appointment as he was appointed only as an alternate Director for Mr Sumner and his appointment occurred just prior to the Christmas office closure period.
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?
In accordance with Listing Rule 3.19B the Company enters into an agreement with all Directors pursuant to which Directors are obliged to provide the necessary information to the Company to enable it to disclose to ASX details of Directors' interests in securities, and in contracts relevant to securities. This Agreement is included in the induction pack provided to Director's upon their appointment. Mr Grant has executed such an Agreement to ensure compliance with ASX Listing Rule 3.19B.
- 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?

The Company has clarified its existing induction procedures in relation to the
appointment of Alternate Directors and Executive Directors as well as Non-Executive Directors.
Yours faithfully
$Q_{\epsilon}$
Jessica Lyons $\mathrel{\mathcal{L}}$ ompany Secretary SERVICE STREAM LIMITED

ASX Compliance Pty Ltd ABN 26 087 780 489 Level 45 Rialto South Tower 525 Collins Street Melbourne VIC 3000
GPO Box 1784 Melbourne VIC 3001
Telephone 61 3 9617 8658 Facsimile 61 3 9614 0303 www.asx.com.au
10 February 2011
Ms Jessica Lyons Company Secretary Service Stream Limited Level 1, 355 Spencer Street West Melbourne VIC 3003
By email
Dear Jessica,
Service Stream Limited (the "Company")
We refer to the following;
-
- The Appendix 3X lodged by the Company with ASX on 4 February 2011 for Mr Robert Gerald Grant.
-
- 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.
-
- 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.
- 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.
As the Appendix 3X indicated that the director was appointed on 21 December 2010 it appears that the Appendix 3X should have been lodged with ASX by 30 December 2011. As the Appendix 3X was lodged on 4 February 2011, it appears that the Company may be in breach of 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 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 was lodged late.
-
- 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?
-
- 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 [email protected] or by facsimile on facsimile number (03) 9614 0303. 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 (i.e. before 9.30 a.m. E.D.S.T.) on Tuesday, 15 February 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
[Sent electronically without signature]
Darren Collins Senior Adviser, Listings