ALARA RESOURCES LIMITED — Director's Dealing 2022

Jul 18, 2022

Alara Resources Limited A.B.N. 27 122 892 719 Suite 1.02, 110 Erindale Road, Balcatta WA 6021, Australia

Telephone | +61 8 9240 4211 Facsimile | +968 2449 2491 Web | www.alararesources.com Email | cosec@alararesources.com

19 July 2022

==> picture [122 x 58] intentionally omitted <==

PO Box 963, Balcatta WA 6914

ASX (Perth) Level 40, Central Park 152-158 St George’s Terrace Perth WA 6000

By Email: listingscomplianceperth@asx.com.au

Alara Resources Limited (“AUQ” or “the Company”)

We refer to your letter dated 14 July 2022, and provide the following responses as requested:

1. Please explain why the notice was lodged late.

The late lodgement of the Appendix 3Y was an administrative oversight.

2. What arrangements does AUQ have in place under Listing Rule 3.19B with its Directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?

The Company acknowledges its disclosure obligations under Listing Rule 3.19A and has in place policies to enable it to comply with its continuous and other disclosure obligations (see, for example, the Continuous Disclosure Policy , referred to in section 5.1 of the Company’s Corporate Governance Statement). In particular, it is a provision of the agreements which the Company has with each of its Directors that they give the Company the information within their knowledge which it requires to enable it to comply with LR 3.19A and related rules.

In this case the Company was aware of the change in the Director’s interests in the securities concerned without the need for him to specifically inform the Company, as the Company arranged for the issue of the securities to the Director, pursuant to the approval of Shareholders at its 2021 Annual General Meeting. Despite the above, lodgement of an Appendix 3Y reflecting that information at the required time was overlooked by inadvertence.

3. If the current arrangements are inadequate or not being enforced, what additional steps does AUQ intend to take to ensure compliance with Listing Rule 3.19B?

It is considered that the Company’s current arrangements are adequate and are enforced, with the exception of an inadvertent breach.

For further information, please contact the writer.

Yours faithfully

Stephen Gethin Chairman

==> picture [56 x 56] intentionally omitted <==

ASX Code | AUQ

==> picture [455 x 5] intentionally omitted <==

==> picture [33 x 50] intentionally omitted <==

14 July 2022

Mr Dinesh Agarwal Company Secretary Alara Resources Limited

By email: dinesh@fortunaadvisors.com.au

Dear Mr Agarwal

Alara Resources Limited (‘AUQ’): Appendix 3Y – Change of Director’s Interest Notice Query

ASX refers to the following:

1. AUQ’s Appendix 3Y lodged on the ASX Market Announcements Platform (‘MAP’) on 11 July 2022 for Atmavireshwar Sthapak (the ‘Notice’).

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

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) including whether the change occurred during a closed period where prior written clearance was required and, if so, whether prior written clearance was provided. 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.’

1. Listing rule 3.19B which states that:

‘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 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.’

The Notice indicates that a change in Mr Sthapak’s notifiable interests occurred on 23 December 2021. It appears that the Notice was not lodged with ASX within 5 business days of that change. Consequently, AUQ may have breached Listing Rules 3.19A and/or 3.19B. It also appears that Mr Sthapak may have breached section 205G of the Corporations Act 2001 (Cth).

ASX Customer Service Centre 131 279 | asx.com.au

ASX Limited [[Listings]]

==> picture [455 x 5] intentionally omitted <==

Request for Information

Under Listing Rule 18.7, we ask that you answer each of the following questions 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 .

1. Please explain why the Notice was lodged late.

2. What arrangements does AUQ have in place under Listing Rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?

3. If the current arrangements are inadequate or not being enforced, what additional steps does AUQ intend to take to ensure compliance with Listing Rule 3.19B?

When and where to send your response

This request is made under Listing Rule 18.7. Your response is required as soon as reasonably possible and, in any event, by no later than 11:00 AM AWST Tuesday, 19 July 2022 . 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, AUQ’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 and may require AUQ to request a trading halt immediately.

Your response should be sent to me by e-mail at ListingsCompliancePerth@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.

Trading halt

If you are unable to respond to this letter by the time specified above, you should discuss with us whether it is appropriate to request a trading halt in AUQ’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 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 .

Suspension

If you are unable to respond to this letter by the time specified above, ASX will likely suspend trading in AUQ’s securities under Listing Rule 17.3.

2/3 ASX Customer Service Centre 131 279 | asx.com.au

==> picture [455 x 5] intentionally omitted <==

Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to AUQ’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 AUQ’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.

Release of correspondence between ASX and entity

We reserve the right to release a copy of this letter, your reply and any other related correspondence between us to the market under Listing Rule 18.7A.

Questions

If you have any questions in relation to the above, please do not hesitate to contact me.

Yours sincerely

Stephanie Patchell

Senior Adviser, Listings Compliance (Perth)

3/3 ASX Customer Service Centre 131 279 | asx.com.au