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CONNECTED MINERALS LIMITED — Director's Dealing 2013
Oct 3, 2013
64669_rns_2013-10-03_bcae977d-9534-404e-b9e9-85ff7c5c8930.pdf
Director's Dealing
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Leopard Resources NL
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PO Box 8 • West Perth • Western Australia • 6872 T: +61 (0)8 9381 2517 F: +61 (0)8 9381 5853 ABN 99 009 076 233
4 October 2013
Shannon Nicholson Adviser, Listings Compliance (Perth) ASX Compliance Pty Ltd Level 8, Exchange Plaza 2 the Esplanade PERTH WA 6000
Dear Shannon
I refer to your letter dated 2 October 2013 in relation to the Appendix 3y for Mr Richard Griffin lodged on 25 September 2013 and respond as follows:
1 The Appendix 3y was lodged late due to an administrative oversight on the part of the company secretary. The oversight was confirmed when the Company reconciled the Directors’ shareholdings when preparing the annual report to shareholders.
2 Under the Company’s corporate governance policy all Directors must inform the Company Secretary via email as soon as possible following the acquisition or sale of securities in the Company. The relevant director had notified the secretary appropriately and the secretary had correspondingly prepared an Appendix 3y. It is not known why the disclosure was not then lodged on the announcements platform within the allowed timeframe.
3 The Company believes that its current policies are adequate for Compliance with Listing Rule 3.19B. The Officers of the Company are aware of their obligations regarding ‘notifiable interests of a Director’.
Kind regards
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Damon Sweeny Company Secretary
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ASX Compliance Pty Limited ABN 26 087 780 489 Level 8 Exchange Plaza 2 The Esplanade PERTH WA 6000 GPO Box D187 PERTH WA 6840
Telephone 61 8 9224 0000 Facsimile 61 8 9221 2020 www.asx.com.au
2 October 2013
Mr Damon Sweeny Company Secretary Leopard Resources NL 32 Barker Street SUBIACO WA 6008
Dear Damon
Leopard Resources NL (the “Company”)
We refer to the following:
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The Company’s announcement lodged with ASX Ltd (“ASX”) on 25 September 2013 regarding a change of director’s interest notice for Mr Richard Griffin (“Appendix 3Y”).
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Listing rule 3.19A which requires an entity to tell ASX the following:
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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:
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On the date that the entity is admitted to the official list.
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On the date that a director is appointed.
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The entity must complete an Appendix 3X and give it to ASX no more than 5 business days after the entity’s admission or a director’s appointment.
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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). The entity must complete an Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.
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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 an Appendix 3Z and give it to ASX no more than 5 business days after the director ceases to be a director.
- Listing rule 3.19B which states as follows.
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.
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ASX Compliance Pty Limited ABN 26 087 780 489 Level 8 Exchange Plaza 2 The Esplanade PERTH WA 6000 GPO Box D187 PERTH WA 6840
Telephone 61 8 9224 0000 Facsimile 61 8 9221 2020 www.asx.com.au
- The Companies Update dated 27 June 2008, reminding listed entities of their obligation to notify ASX within 5 business days of the notifiable interests in securities held by each director and outlining the action that ASX would take in relation to breaches of listings rules 3.19A and 3.19B.
As the Appendix 3Y indicates a change in Mr Griffin’s notifiable interest occurred on 30 May 2013 the Appendix 3Y should have been lodged with the ASX by 6 June 2013. As the Appendix 3Y was lodged on 25 September 2013 it appears that the Company may be in breach of listing rules 3.19A and/or 3.19B.
Please note that ASX is required to record details of breaches of the listing rules by listed companies for its reporting requirements.
ASX reminds the Company of its contract with ASX to comply with the listing rules. In the circumstances ASX considers that it is appropriate that the Company make necessary arrangements to ensure there is not a reoccurrence of a breach of the listing rules.
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”, we ask that you answer each of the following questions.
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Please explain why the Appendix 3Y was lodged late.
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What arrangements does the Company have in place 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 the Company intend to take to ensure compliance with listing rule 3.19B?
Your response should be sent to me by e-mail to [email protected] or by facsimile on facsimile number (08) 9221 2020. It should not be sent to the Company Announcements Office.
A response is requested as soon as possible and, in any event, not later than 11:30AM WST on Friday, 4 October 2013.
Under listing rule 18.7A, a copy of this query and your response will be released to the market, so your response should be in a form suitable for release and must separately address each of the questions asked. If you have any queries or concerns, please contact me immediately.
Yours sincerely
[ sent electronically without signature]
Shannon Nicholson Senior Adviser, Listings Compliance (Perth)
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