Cromwell Funds Management

Boardroom Pty Limited (ABN 14 003 209 836) ('BoardRoom') provides a comprehensive range services to listed and unlisted entities, public, private and member based organisations.

Protecting personal information provided to us is important and integral to our business philosophy and ethics.

We are required to comply with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). We trust the information contained in this Privacy Policy will give you an understanding how BoardRoom collects, manages, uses and safeguards your personal information. We understand that privacy is important to you.

By accessing the website, www.boardroomlimited.com.au or using our services, you agree to be bound by the terms of this Privacy Policy.

This Privacy Policy (which is current as at 12 March 2014) may be amended from time to time. Amendment may be required to take account of legislative changes or changes to BoardRoom's practices which may affect the manner in which we maintain information.

• Securities registry management: including maintenance of the register of names and addresses of securityholders; facilitation of communications from issuers to securityholders; facilitation of the payment of dividends and distributions to securityholders and the handling securityholder enquiries
• Employee equity plan management which involves the provisions of similar services to those provided for securities registry maintenance;
• Ballot and Voting management: which involves the preparations for and conduct of an election or ballot; provision of information to eligible voters and the collection and counting of votes in accordance with any applicable legislation or rules;
• Provision of corporate secretarial support: where staff of BoardRoom may be named as company secretary for proprietary or public companies or may assist by providing administrative support to the person already named as company secretary; and
• Payroll administration; ranging from a record keeping function to the actual payment to relevant employees.

In its capacity as a securities registrar, employee equity plan administrator, provider of company secretarial support services and payroll administrator, BoardRoom collects personal information including name and address details, securityholding or plan participation details and balances, bank account details, tax file numbers, dates of birth, telephone numbers and email addresses.

How Information Is Collected And Stored

BoardRoom only collects personal information where it is necessary to enable the provision of services.

If you do not provide some or all of the requested personal information, BoardRoom may not be able to provide services (such as securities registry or plan administration services) to you.

Personal information may be provided to us:

• directly by securityholders or employee equity plan participants, verbally, on application forms, advices of banking instructions, tax file numbers, statutory declarations, or other documentation or through the online internet based facilities available for use by securityholders or employee plan participants, all of which are associated with the administration of a securities register or an employee equity scheme;
• by securities issuers;
• by securities exchanges;
• by stockbrokers or financial advisers;
• by users of the internet based facilities offered by BoardRoom;
• by clients who use our voting management services;
• by clients who use our payroll administration services or the employees of those clients; and
• by directors and/or other officers of companies to which we provide company secretarial services.

Personal information is stored in secure electronic databases and where applicable, on paper documents. Any information on paper documents is stored in secure, offsite storage facilities for a period of time determined by law or client's instructions. The databases and offsite storage facilities are both located within Australia.

BoardRoom takes reasonable steps to ensure the security of personal information held by it from such risks as loss or unauthorised access, destruction, use, modification or disclosure.

Cookies and Web logs

We use cookies and web logs on our website to improve its functionality. Cookies are a small text file that our websites may place on your computer and collect information such as your internet protocol address, your computer's operating system, browser type and traffic patterns.

You may adjust your internet browser to disable cookies or to inform you when one is being used. If you choose to disable cookies, you may be unable to access certain areas of our website.

Sometimes our website contains links to other websites for convenience and information. When you access a website other than www.boardroomlimited.com.au please understand that we are not responsible for the privacy practices of that site.

Personal information is collected and used to provide related services that are connected to the initial purpose:

• Maintenance of security registers which securities issuers are obliged to maintain under the Corporations Act 2001 (Cth) ("Corporations Act");
• Provision of registry and employee equity plan administration related services; payment of dividends/distributions, corporate communications including notice of meetings, financial results, annual reports and other information that securities issuers may wish to communicate to their securityholders or participants in the employee equity plan;
• Facilitating compliance by BoardRoom's clients with legal and regulatory requirements; or
• Provision of voting management related services; distribution of voting information, collection and counting of votes.

Personal information may also be disclosed to the securities issuer, regulatory authorities including the Australian Taxation Office, authorised security brokers or authorised financial advisers and external providers of services such as IT support, printers and mail houses who would assist BoardRoom in providing services.

If, in accordance with the provisions of the Corporations Act the issuer of the securities you hold (including where you hold securities as a participant in an employee equity scheme) approves, you may be sent marketing material in addition to general corporate communications. You may elect not to receive marketing material by contacting BoardRoom.

Disclosure may also be required or authorised by or under law, to be made to law enforcement agencies, government agencies and courts. This could be for a number of reasons including prevention or investigation of a fraud or crime (or a suspected fraud or crime).

BoardRoom does not sell, trade, lease or rent personal information.

Unless required by law, BoardRoom will not disclose personal information to an overseas recipient. However, when requested by one of its (BoardRoom's) clients, a related party of BoardRoom wherever situated (including in Hong Kong, Malaysia, Singapore and China) may use personal information collected by BoardRoom to assist BoardRoom in providing services to the BoardRoom client which made the request.

You have the right to access, correct and update the personal information that we hold about you.

To ensure the integrity and safety of personal information, BoardRoom will only disclose, correct and update information if our internal procedures are satisfied.

Depending on the nature of your request, your personal information may be stored in our archives which are not current records. You might be asked to complete a personal information request form and in certain cases we may charge you a fee for this service but will inform you at the time.

If your personal information is relating to a securities holding which is a broker sponsored CHESS holding, you will need to contact that broker to update your registered name or address.

If you have any questions or comments about our Privacy Policy or if you wish to make a complaint about how we have handled personal information about you, please contact BoardRoom's Privacy Officer who will try to resolve the matter within ten (10) business days. If we are unable to resolve the matter within that time, we will contact you to let you know how long it will take to resolve the complaint or, if more appropriate, suggest the matter be referred to the Privacy Commissioner. BoardRoom's Privacy Officer contact details are:

privacyofficer@boardroomlimited.com.au

or

The Privacy Officer
Boardroom Pty Limited
GPO Box 3993
Sydney NSW 2001