35ec93be-0b80-4b07-9bdc-cce6faf0f23f.pdf
18 July 2016
Mr Dale Allen
Senior Adviser - ASX Listing Compliance ASX Limited
Level 40, Central Park
152-158 St Georges Terrace PERTH WA 6000
Dear Mr Allen,
RESPONSE TO 18 JULY 2016 PRICE AND VOLUME QUERY
216 Balcatta Road, Balcatta Western Australia 6021
PO Box 1262, Osborne Park Western Australia 6916
Tel: +61 (0) 8 9445 4020
Fax: +61 (0) 8 9445 4042
[email protected] www.imdexlimited.com ABN 78 008 947 813
We refer to the price and volume query from ASX Limited ("ASX") of 18 July 2016 to Imdex Limited ("the Company"). We provide the following response:
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The Company is not aware of any market sensitive information that has not been released to the market.
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Not Applicable.
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The Company is not aware of any reason for the price or volume change in recent trading in the securities.
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The Company confirms that it is in compliance with the ASX Listing Rules and, in particular, Listing Rule 3.1.
Yours faithfully
Imdex Limited
Paul Evans
Company Secretary
Providing innovative drilling fluids and advanced down hole instrumentation worldwide.
18 July 2016
Mr Paul Evans Company Secretary Imdex Limited
By email: [email protected]
Dear Mr Evans
Imdex Limited (the "Entity"): ASX Price and Volume Query
We have noted a change in the price of the Company's securities from a closing price of $0.235 on Tuesday, 12 July 2016, to an intraday high of $0.36 at the time of writing today, 18 July 2016. We have also noticed an increase in the volume of trading in the Company's securities over this period.
In light of the price increase and volume increase, ASX asks you to respond separately to each of the following questions:
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Is the Entity aware of any information concerning it that has not been announced to the market which, if known by some in the market, could explain the recent trading in its securities?
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If the answer to question 1 is "yes":
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Is the Entity relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1?
Please note that the recent trading in the Entity's securities would suggest to ASX that such information may have ceased to be confidential and therefore the Entity may no longer be able to rely on Listing Rule 3.1A. Accordingly, if the answer to this question is "yes", you need to contact us immediately to discuss the situation.
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Can an announcement be made immediately?
Please note, if the answer to this question is "no", you need to contact us immediately to discuss requesting a trading halt (see below).
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If an announcement cannot be made immediately, why not and when is it expected that an announcemant will be made?
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If the answer to question 1 is "no", is there any other explanation that the Entity may have for the recent trading in its securities?
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Please confirm that the Entity is in compliance with the Listing Rules and, in particular, Listing Rule 3.1.
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ASX Compliance Pty Limited ABN 26 087 780 489
Level 40, Central Park 152‐158 St George's Terrace Perth WA 6000
www.asx.com.au Customer service 13 12 79
T 61 8 9224 0000
When and where to send your response
This request is made under, and in accordance with, Listing Rule 18.7. Your response is required as soon as reasonably possible and, in any event, by no later than 01:00 pm (WST) today, 18 July 2016. If we do not have your response by then, ASX will have no choice but to consider suspending trading in the Entity's securities under Listing Rule 17.3.
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, the Entity'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.
ASX reserves the right to release a copy of this letter and your response on the ASX Market Announcements Platform under Listing Rule 18.7A. Accordingly, your response should be in a form suitable for release to the market.
Your response should be sent to me by e‐mail at [email protected] and [email protected]. 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.
Listing Rule 3.1
Listing Rule 3.1 requires a listed entity to give ASX immediately any information concerning it that a reasonable person would expect to have a material effect on the price or value of the entity's securities. Exceptions to this requirement are set out in Listing Rule 3.1A.
The obligation of the Entity to disclose information under Listing Rules 3.1 and 3.1A is not confined to, nor is it necessarily satisfied by, answering the questions set out in this letter.
In responding to this letter, you should have regard to the Entity's obligations under Listing Rules 3.1 and 3.1A and also to Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 - 3.1B.
Trading halt
If you are unable to respond to this letter by the time specified above, or if the answer to question 1 is "yes" and an announcement cannot be made immediately, you should discuss with us whether it is appropriate to request a trading halt in the Entity's securities under Listing Rule 17.1.
If you wish a trading halt, you must tell us:
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the reasons for the trading halt;
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how long you want the trading halt to last;
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the event you expect to happen that will end the trading halt;
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that you are not aware of any reason why the trading halt should not be granted; and
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any other information necessary to inform the market about the trading halt, or that we ask for.
We may 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.
If you have any queries or concerns about any of the above, please contact me immediately.
Yours sincerely
[sent electronically without signature]
Dale Allen
Senior Adviser, ASX Listings Compliance (Perth)