CLASSIC MINERALS LTD — Director's Dealing 2023

Sep 18, 2023

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C LASSIC MINERALS LIMITED

71 Furniss Rd, Landsdale Western Australia 6065 ASX: CLZ | ABN 77 119 484 016 contact@classicminerals.com.au

Australian Securities Exchange Limited,

Level 40, Central Park, 152-158 St George’s Terrace, PERTH, WA, 6000

Attention: Mr Raj Logarajah

Dear Sir

We refer to your letter dated 14 September 2023.

We acknowledge Mr Lester’s Change of Director’s Interest Notice was lodged late.

This was due to an administrative oversight on our part.

At present we have been relying on the directors informing the Company Secretary of any changes in their shareholdings and seeking authority to trade on black out dates.

As such, we have reminded the directors of their obligations to notify us in a timely manner so as to ensure that Classic Minerals Limited is compliant with the ASX rules.

We have also implemented additional, daily monitoring of the director’s shareholdings.

Please do not hesitate to contact us if you have any queries.

Yours sincerely

Madhukar Bhalla (FGIA FCIS)

Company Secretary

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14 September 2023 Reference: 80194

Mr Madhukar Bhalla Company Secretary Classic Minerals Limited

By email: madhu@classicminerals.com.au

Dear Mr Bhalla

Classic Minerals Limited (‘CLZ’): Appendix 3Y – Change of Director’s Interest Notice Query

ASX refers to the following:

1. CLZ’s Appendix 3Y lodged on the ASX Market Announcements Platform (‘MAP’) on 12 September 2023 for Mr John Lester (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 Lester’s notifiable interest occurred on 30 August 2023. It appears that the Notice should have been lodged with ASX by 6 September 2023. Consequently, CLZ may have breached Listing Rules 3.19A and/or 3.19B. It also appears that Mr Lester may have breached section 205G of the Corporations Act 2001 (Cth).

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

ASX Limited [[Listings]]

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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 Appendix 3Y was lodged late.

2. What arrangements does CLZ 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 CLZ 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 1:00 PM AWST Tuesday, 19 September 2023 . 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, CLZ’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 CLZ 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 CLZ’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 CLZ’s securities under Listing Rule 17.3.

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

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Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to CLZ’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 CLZ’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

ASX reserves the right to release all or any part 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

Raj Logarajah

Senior Adviser, Listings Compliance

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