VINYL GROUP LTD — Regulatory Filings 2021

Jul 1, 2021

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1 July 2021

Maria Clemente Adviser, Listings Compliance ASX Compliance Pty Ltd 20 Bridge Street Sydney NSW 2000

By email: Maria.Clemente@asx.com.au

Dear Ms Clemente,

Response to Query Reference: 36287

Jaxsta Limited (ACN: 106 513 580) responds to your query dated 30 June 2021, regarding the delay in filing appendix 3Y as filed on 29 June 2021. The three questions in particular are addressed below:

1. Please explain why the Appendices 3Y were lodged late.

The appendices 3Y were part of a package for filing along with the amended 3B and Appendix 3G. During the entry of the amendment on the ASX portal, we could not complete the action as the portal was not processing the amendment correctly. During that failed attempt, we had incorrectly marked the 3Ys as processed in our internal tracker. When we resolved the Appendix 3B amendment via a manual submission, we did not include the 3Ys as they were marked as completed in our documentation. Upon regular review of our ASX page and website, the error was noticed and we uploaded the documents for compliance.

In this case, the transactions that gave rise to the issue of options to Directors were already documented in the Notice of Meeting dated 5 May 2021, the results of the EGM published on 11 June and the aforementioned appendix 3B, as such the market was informed, but the complete set of appendices should have been filed on time as intended.

1. What arrangements does JXT have in place under Listing Rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?

Directors provide their updated information on to our live interest register and our announcement release checklist verifies the documents required for the different transactions.

1. If the current arrangements are inadequate or not being enforced, what additional steps does JXT intend to take to ensure compliance with Listing Rule 3.19B?

The current system works as the filing was prepared and the error was discovered through the procedures in place and all previous filings had been issued correctly. We are however in the process of implementing a more automated system with approval mechanisms that allow and record multiple approval signoff to provide further quality control. This system is expected to replace the current process in the next quarter as part of our continuing process and operational improvements.

Regards,

Jorge Nigaglioni Director & Company Secretary

Jaxsta

Level 1, Suite 2, 113-115 Oxford Street, DARLINGHURST, NSW, 2010 , AUSTRALIA Ph: +61 2 8317 1000

Jaxsta.com ABN 29 605 344 054 ACN 605 344 054

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30 June 2021

Reference: 36287

Mr Jorge Nigaglioni Director, Chief Financial Officer and Company Secretary Jaxsta Ltd

By email: jorge.nigaglioni@jaxsta.com

Dear Mr Nigaglioni

Jaxsta Ltd (‘JXT’): Appendix 3Y – Change of Director’s Interest Notice Query

ASX refers to the following:

1. JXT’s Appendices 3Y lodged on the ASX Market Announcements Platform (‘MAP’) on 29 June 2021 for Ms Linda Jenkinson and Mr Brett Cottle (the ‘Notices’);

2. 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.’

1. Listing rule 3.19B which states that:

‘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 Notices indicate that a change in each of Ms Jenkinson and Mr Cottle’s notifiable interests occurred on 16 June 2021. It appears that the Notices should have been lodged with ASX by 23 June 2021. Consequently, JXT may have breached Listing Rules 3.19A and/or 3.19B.

ASX Customer Service Centre 131 279 | asx.com.au

ASX Limited [[Listings]]

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Request for Information

Under Listing Rule 18.7, we ask that you answer each of the following questions 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 .

1. Please explain why the Appendices 3Y were lodged late.

2. What arrangements does JXT have in place under Listing Rule 3.19B 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 JXT intend to take to ensure compliance with Listing Rule 3.19B?

When and where to send your response

This request is made under Listing Rule 18.7. Your response is required as soon as reasonably possible and, in any event, by no later than 3:30 PM AEST Friday, 2 July 2021 . You should note that if the information requested by this letter is information required to be given to ASX under Listing Rule 3.1 and it does not fall within the exceptions mentioned in Listing Rule 3.1A, JXT’s obligation is to disclose the information ‘immediately’. This may require the information to be disclosed before the deadline set out in the previous paragraph and may require JXT to request a trading halt immediately.

Your response should be sent to me by e-mail. It should not be sent directly to the ASX Market Announcements Office. This is to allow me to review your response to confirm that it is in a form appropriate for release to the market, before it is published on the ASX Market Announcements Platform.

Trading halt

If you are unable to respond to this letter by the time specified above, you should discuss with us whether it is appropriate to request a trading halt in JXT’s securities under Listing Rule 17.1. If you wish a trading halt, you must tell us:

• 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; and

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

We require the request for a trading halt to be in writing. The trading halt cannot extend past the commencement of normal trading on the second day after the day on which it is granted. You can find further information about trading halts in Guidance Note 16 Trading Halts & Voluntary Suspensions .

Suspension

If you are unable to respond to this letter by the time specified above, ASX will likely suspend trading in JXT’s securities under Listing Rule 17.3.

Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to JXT’s obligations under Listing Rules 3.1 and 3.1A and also to Guidance Note 8 Continuous Disclosure : Listing Rules 3.1 – 3.1B. It should be noted that JXT’s obligation

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ASX Customer Service Centre 131 279 | asx.com.au

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to disclose information under Listing Rule 3.1 is not confined to, nor is it necessarily satisfied by, answering the questions set out in this letter.

Release of correspondence between ASX and entity

We reserve the right to release a copy of this letter, your reply and any other related correspondence between us to the market under Listing Rule 18.7A.

Questions

If you have any questions in relation to the above, please do not hesitate to contact me.

Yours sincerely

Maria Clemente

Adviser, Listings Compliance (Sydney)

3/3 ASX Customer Service Centre 131 279 | asx.com.au