Shareholder communications policy

1. Overview

1.1 The purpose of this policy is to promote effective communication with shareholders and encourage effective participation at general meetings of ApplyDirect Limited ACN 123 129 162 (Company).

1.2 The Company will ensure that:

(a) materials detailed in this policy are maintained and updated on the Company's website,;

(b) shareholder communications are distributed to shareholders in accordance with the Corporations Act 2001 (Cth) (Corporations Act) and listing rules (Listing Rules) of ASX Limited (ASX); and

(c) it will use available channels and technologies to communicate widely and promptly to shareholders.

2. ASX announcements

2.1 The Company makes announcements to the ASX in accordance with the Listing Rules and the Corporations Act.

2.2 Announcements made by the Company to the ASX will be made available, subject to applicable securities laws, to shareholders:

(a) on the 'Investor Relations' section of the Company's website; and

(b) under the 'Company Announcements' section of the ASX website.

3. Company's share registry

3.1 The Company will use all reasonable endeavours to ensure Shareholders are able to access information relevant to their shareholding via the website of the Company's share registry. Shareholders who do not have access to the internet should contact the Company's share registry with any enquiries relating to their shareholdings or alternatively contact the Company Secretary.

3.2 The ASX code for the Company is 'AD1'.

3.3 Shareholders will be given the option to receive communications from, and send communications to, the Company and its share registry electronically.

4. Annual general meetings

4.1 The Company intends to hold its annual general meeting (AGM) in November each year. The specific date, time and location of each AGM will be detailed:

(a) in the relevant notice of meeting; and

(b) on the Company's website.

Alternatively, shareholders can contact the Company's share registry or the Company Secretary directly to obtain this information.

4.2 The notice of meeting will be distributed to all shareholders prior to the AGM within the timeframe set by the Corporations Act and the Company's constitution. The full text of the notice of meeting will also be available via the 'Investor Relations' section of the Company's website.

4.3 Shareholder meetings are an opportunity for shareholders and other stakeholders to hear from and put questions to the board of the Company (Board), its management and the external auditor. Shareholders may attend the meeting in person (including by any relevant technological means made available by the Company) or by proxy, representative or attorney.

4.4 The chairman will provide reasonable time following the consideration of reports for questions and comment on relevant matters (including questions or comments communicated to the Company by absent shareholders).

4.5 The chairman's address (and any address by the Chief Executive Officer) will be released to the market immediately prior to the commencement of the AGM. It, along with any webcast made or transcript kept, will be available to shareholders via the Company's website in the same manner as other ASX announcements.

5.Annual report

5.1 The annual report contains key financial information about the Company, as well as important operating and corporate information. As permitted by the Corporations Act, the default method of receiving the Company's annual reports is electronically via the 'Investor Relations' section of the Company's website (under 'Annual Reports'). A printed copy of the annual report will only be sent to shareholders who elect to receive one. Shareholders who wish to receive a printed copy of the annual report will need to contact the Company's share registry.

5.2 The annual report will be available to all shareholders prior to the AGM within the timeframe set by the Corporations Act. It will usually be published in October each year.

6. Half-year and full-year results

6.1 The preliminary financial results for the 31 December half-year end are reported in February each year. The financial results for the 30 June full-year end are reported in August each year.

6.2 As the half-year and full-year results are announced to the ASX pursuant to the Listing Rules, they will be available to shareholders in the same manner as other ASX announcements. In addition, the results will be accessible via the 'Investor Relations' section of the Company's website (under 'ASX Releases').

7. Corporate governance

7.1 In accordance with Recommendation 6.1 of the ASX Corporate Governance Council Principles and Recommendations (ASX Principles), the Company has a 'Corporate Governance' section on the Company's website.

7.2 The Company's annual corporate governance statement is prepared in accordance with the Listing Rules. It is contained in or accompanies the annual report each year and also is or will be available under the 'Corporate Governance' section of the Company's website.

7.3 In accordance with Recommendation 1.1 of the ASX Principles, the Company has a formal board charter, containing details of the functions and responsibilities of the Board. To assist the Board in fulfilling its duties and responsibilities, it has established two Board committees:

(a) the audit and risk committee; and

(b) the nomination and remuneration committee.

Each of these committees has a formal charter. The Board and committee charters, along with other corporate governance policies and documents, are also available to shareholders from the 'Corporate Governance' section of the Company's website.

8. Media releases

Access to the Company's media releases is available from the 'Investor Relations' section of the Company's website (under 'ASX Releases'). Where applicable, media releases will also be released to the market via the ASX.

9. Investor and analyst briefings

9.1 At the time of announcement to the ASX of the Company's half-year and full-year results the Company may conduct investor and analyst briefings. Investor and analyst briefings may occur at other times during the year as the Board deems appropriate.

9.2 If and when investor and analyst briefings occur at other times during the year, any presentation materials provided and webcasts or transcripts (if kept) will be made available to all shareholders via the 'Investor Relations' section of the Company's website and will be released to the market prior to the briefings.

10. Information for beneficial owners

Beneficial owners of the Company securities are encouraged to contact the Company's share registry to arrange the direct receipt of shareholder materials.

11. Other information

It is intention that the Company's website will also contain other general information concerning the Company. Appendix A lists the type of information that the Company will ordinarily seek to provide on its website. No guarantee is provided that all the information listed in Appendix A will be available at all times. Further, while it is intended the information will be regularly updated, no guarantee is given that it will be accurate and complete at all times.

12. Publishing and updating the policy

In compliance with the ASX Principles, this policy or a summary of its main provisions will also be published on the Company's website. The Board may approve updates and amendment of this policy from time to time.

13. Questions about the policy and its application

Employees, shareholders, investors and members of the public should direct their questions about this policy and its application to the Company Secretary, the details of which are set out in section 3.

14. Approved and adopted

This policy was approved and adopted by the Board on 24 November 2015.

Appendix A

It is intention that the Company's website will ordinarily contain the following general information concerning the Company:

1. the names, photographs and brief biographical information of each of the Company's directors and senior executives;

2. the Company's board charter and the charters of each of its board committees;

3. the Company's corporate governance policies and its other corporate governance materials;

4. copies of the Company's annual reports and financial statements;

5. copies of media releases and announcements to ASX that the Company makes;

6. copies of notices of meetings of shareholders and any accompanying documents;

7. an overview of the Company's current structure and business;

8. a summary of the Company's history;

9. a key events calendar showing the expected dates in the forthcoming year for:

(a) the annual general meeting of the Company;

(b) books' closing dates for determining entitlements to dividends or distributions; and

(c) ex-dividend and payment dates for dividends or distributions;

10. if the Company has different classes of securities on issue, a brief description of those different classes and the rights attaching to them;

11. contact details (preferably for a named individual) for enquiries from shareholders, analysts or the media;

12. contact details for the Company's securities registry; and

13. to the extent relevant, links to download key shareholder forms, such as transfer and transmission forms, dividend and distribution reinvestment plan forms.