ZICOM GROUP LIMITED — Director's Dealing 2010

Sep 16, 2010

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ABN 62 009 816 871 Zicom Group Limited

38 Goodman Place, Murarrie, Queensland 4172 • Tel: (07) 3908 6088 • Fax: (07) 3390 7962

17 September 2010

ASX Compliance Pty Limited Level 5 Riverside Centre 123 Eagle Street Brisbane QLD 4000

Attention: Mr Rohan Abeyewardene

Dear Sir

Appendix 3X Initial Director’s Interest Notice

We refer to your letter dated 16 September 2010 and would like to clarify as follows: -

1. The Appendix 3X was submitted by Mr Sim Kok Yew to the Company Secretarial Office on 6 July 2010. Mr Sim Kok Yew’s submission was received in the midst of a rush to finalise our June accounts for audit to meet audit and reporting deadlines while at the same time, we were going live with our Enterprise Resource Planning (ERP) system in our Australian subsidiary, Cesco Australia Ltd that integrates our operations and accounting system as part of our Group’s efforts to strengthen our controls and reporting requirements. In the midst of these, the Joint Company Secretaries who are also responsible for the respective areas’ group accounts regrettably overlooked the timely lodgement of Appendix 3X with ASX.

As part of our good practices, the Company Secretaries review the Company’s secretarial records on a regular basis to ensure that records are kept up-to-date and compliance with statutory requirements and listing rules has been strictly adhered to. This omission was detected when the records were reviewed in September and was immediately rectified by the Company Secretary.

1. All directors of the Company are fully aware of their obligations in relation to Listing Rule 3.19A and have been strictly adhering to the rules.

2. We believe our current process for compliance with Listing Rules 3.19B is adequate.

We apologise for the oversight.

Yours faithfully Zicom Group Limited

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Jenny Lim Joint Company Secretary

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16 September 2010

Mr Surendra Kumar Joint Company Secretary Zicom Group Limited 38 Goodman Place MURARRIE QLD 4172

By email: skumar@cescoaustralia.com

ASX Compliance Pty Limited ABN 26 087 780 489 Level 5 Riverside Centre 123 Eagle Street Brisbane QLD 4000

PO Box 7055 Riverside Centre Brisbane QLD 4001

Telephone +61 7 3835 4000 Facsimile +61 7 3832 4114 Internet http://www.asx.com.au

Dear Mr Kumar

Zicom Group Limited (the “Company”) Appendix 3X Initial Director’s Interest Notice

We refer to the following:

1. The Appendix 3X for Sim Kok Yew lodged by the Company with ASX Limited (“ASX”) on Monday, 6 September 2010 (the “Appendix 3X”);

2. Listing rule 3.19A which requires an entity to tell ASX the following:

3. 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). 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

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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.

1. 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.

The Appendix 3X indicates that Sim Kok Yew was appointed as a director on Monday, 5 July 2010. It appears that the Appendix 3X should have been lodged with ASX by Monday, 12 July 2010. Consequently, the Company may be in breach of listing rules 3.19A and/or 3.19B. It also appears that the director 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:

1. Please explain why the Appendix 3X was 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?

3. 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 email at rohan.abeyewardene@asx.com.au or by facsimile on facsimile number (07) 3832 4114. 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 (9.30am EST) on Tuesday, 21 September 2010.

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

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Rohan Abeyewardene Senior Adviser, Issuers (Brisbane)

Copy: Ms Jenny Lim, Joint Company Secretary, Zicom Group Limited

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