Response to ASX Price Query
Released
Released
Announcement PDF
7 November 2017
Ms Hayley Pratt
Adviser, Listings Compliance (Perth)
ASX Compliance Pty Ltd
20 Bridge Street
Sydney NSW 2000
By email: Hayley.Pratt@asx.com.au
By email: tradinghaltsperth@asx.com.au
Dear Hayley
Re: PRICE QUERY
Ventnor Resources Limited (“the Company”) refers to your letter dated 7 November 2017 and
comments as follows:
1.
The Company is not 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 the securities
of the Company.
2.
Not applicable.
3.
The Company is not able to offer any other explanation for the recent trading in its securities,
other than:
(i)
the proposed demerger and in-specie distribution of shares in Delgare Pty Ltd as
outlined in the short form prospectus dated 27 October 2017 and Notice of annual
general meeting of the same date, both released to the market on 30 October 2017;
and
(ii)
the announcement of the new Arrowsmith Silica Sand Project (“Arrowsmith Project”) on
12 October 2017. As part of the ongoing review of the Arrowsmith Project, the
Company has been assessing other silica and construction sand prospects to
complement the Arrowsmith Project. No decision has been made in relation to any
other project.
4.
We confirm that the Company is in compliance with the Listing Rules and, in particular, Listing
Rule 3.1.
5.
We confirm that the Company’s responses have been authorised and approved in accordance
with its published continuous disclosure policy or otherwise by its board or an officer of the
Company with delegated authority from the board to respond to ASX on disclosure matters.
Yours faithfully
Bruce Maluish
Director
7 November 2017
Mr John Geary
Company Secretary
Ventnor Resources Limited
Level 1
6 Thelma Street
WEST PERTH WA 6005
By email: johng@ventnorresources.com.au
Dear Mr Geary
Ventnor Resources Limited (“VRX”): price query
We note the change in the price of VRX’s securities from an intraday low of $0.016 yesterday, Monday 6
November 2017 to an intraday high of $0.026 today, Tuesday 7 November 2017.
In light of this, ASX asks VRX to respond separately to each of the following questions and requests for
information:
1.
Is VRX 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?
2.
If the answer to question 1 is “yes”:
a)
Is VRX relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1?
Please note that the recent trading in VRX’s securities would suggest to ASX that such
information may have ceased to be confidential and therefore VRX 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.
b)
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).
c)
If an announcement cannot be made immediately, why not and when is it expected that an
announcement will be made?
3.
If the answer to question 1 is “no”, is there any other explanation that VRX may have for the recent
trading in its securities?
4.
Please confirm that VRX is in compliance with the Listing Rules and, in particular, Listing Rule 3.1.
5.
Please confirm that VRX’s responses to the questions above have been authorised and approved in
accordance with its published continuous disclosure policy or otherwise by its board or an officer of
VRX with delegated authority from the board to respond to ASX on disclosure matters.
ASX Compliance Pty Limited
ABN 26 087 780 489
20 Bridge Street
Sydney NSW 2000
www.asx.com.au
Customer service 13 12 79
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 not later than 11.00 am AWST on Tuesday 7 November 2017. If we
do not have your response by then, ASX will have no choice but to consider suspending trading in VRX’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, VRX’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 Hayley.Pratt@asx.com.au and
to tradinghaltsperth@asx.com.au. 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 Rules 3.1 and 3.1A
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.
In responding to this letter, you should have regard to VRX’s obligations under Listing Rules 3.1 and 3.1A and
also to Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 – 3.1B.
It should be noted that VRX’s obligation to disclose information under Listing Rule 3.1 is not confined to, nor
is it necessarily satisfied by, answering the questions set out in this letter.
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 VRX’s securities under Listing Rule 17.1.
If you wish a trading halt, you must tell us:
•
the reasons for the trading halt;
•
how long you want the trading halt to last;
•
the event you expect to happen that will end the trading halt;
•
that you are not aware of any reason why the trading halt should not be granted; and
•
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.
Page 2 of 3
If you have any queries or concerns about any of the above, please contact me immediately.
Yours sincerely
[Sent electronically without signature]
Hayley Pratt
Adviser – Listings Compliance (Perth)
Page 3 of 3
Share your feedback
Discover