ZENITH MINERALS LIMITED — Director's Dealing 2009

Sep 10, 2009

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10 September 2009

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Wade Baggott Advisor, Issuers (Perth) Company Announcements Office Australian Securities Exchange Level 8. Exchange Plaza 2 the Esplanade PERTH WA 6000

Dear Wade,

ZINC CO AUSTRALIA LIMITED -Appendix 3Y - Change of Director's Interest Notice.

I refer to your letter dated 9 September 2009 in relation to the recent Appendices 3Y lodged for Messrs Comb, Joyce and Macdonald, and respond as follows:

• 1. Please explain why the Appendices 3Y were lodged late. The movement in the holding was due to the expiry of unlisted options. The late lodgement was due to an inadvertent clerical oversight. We apologise for this oversight.
• 1. 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? Per the Company's Share Trading Policy, directors are aware of the need to advise the company secretary of any dealings in the company's securities. However in this instance, the directors fulfilled their obligations.
• 1. 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 current arrangements are considered adequate.

Yours sincerely

APeredgoylar

Alex Dermedgoglou Joint Company Secretary

Level 3, 33 Ord Street, West Perth, Western Australia 6005 PO Box 1426, West Perth, Western Australia 6872 Tel: (+61-8) 9226 1110 Fax: (+61-8) 9321 0070

ASX Markets Supervision Pty Ltd ABN 26 087 780 489 Level 8. Exchange Plaza 2 the Esplanade Perth WA 6000

PO Box 0187 Perth WA 6840

Telephone 61 8 9224 0000 Facsimile 61 8 9221 2020 www.asx.com.au

9 September 2009

Alex Dermedgoglou Company Secretary Zinc Co Australia Limited Level 3, 33 Ord Street WEST PERTH WA 6005

By fax: 08 9321 0070

Dear Alex

ZINC CO AUSTRALIA LIMITED (the "Company") Appendix 3Y - Change of Director's Interest Notice.

We refer to the following;

• The Appendices 3Y lodged by the Company with ASX Limited ("ASX") on 9 September 2009 for Gary 1. Comb. Rodney Joyce and Stanley MacDonald; and
• Listing rule 3.19A which requires an entity to tell ASX the following: $2.$
• 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.
  • 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). The entity must complete Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.
• The notifiable interests of a director of the entity (or in the case of a trust, a director of the 3.19A.3 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. $3¹$

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 4. 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 Appendices 3Y indicated a change of directors' interests for Mr Comb, Mr Joyce and Mr MacDonald on 30 June 2009, it appears that the Appendices 3Y should have been lodged with the ASX by 7 July 2009. As the Appendices 3Z were lodged on 9 September 2009, 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:

• 1. Please explain why the Appendices 3Y were 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?
• If the current arrangements are inadequate or not being enforced, what additional steps does the 3 Company intend to take to ensure compliance with listing rule 3.19B?

Your response should be sent to me 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 (ie before 7.30 a.m. W.S.T.) on Monday 14 September 2009.

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.

Wade Baggott Adviser, Issuers (Perth)