Cygnus Metals Ltd — Director's Dealing 2020

Oct 8, 2020

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9 October 2020

Ms Elizabeth Harris Manager, Listings Compliance ASX Limited Level 40, Central Park 152-158 St George's Terrace Perth WA 6000

Dear Elizabeth,

RE: Appendix 3Y - Change of Director's Interest Query

In relation to the late lodgement of the Appendix 3Y's for each of Messrs Bohm, Jackson, Shorrocks, and Hardcastle, we advise as follows:

1. The Appendix 3Y's were lodged late due to an administrative oversight. Each Director has confirmed that they are aware of their obligations in this respect.

2. The Company has procedures in place under which Directors' are obliged to advise the Company Secretary when a change takes place in relation to a notifiable interest. These procedures are in accordance with the Company's Continuous Disclosure Policy and Securities Trading Policy.

3. Whilst the Company considers its current arrangements are adequate for ensuring timely notification, and that failure to do so on this occasion was due to an administrative error, it has nevertheless reviewed its procedures to ensure that it meets its disclosure obligations.

Yours sincerely,

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Michael Naylor Company Secretary Cygnus Gold Limited

Cygnus Gold Limited Level 3, 24 Outram Street, West Perth WA 6005 PO Box 571, West Perth WA 6872 E: admin@cygnusgold.com W: www.cygnusgold.com

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6 October 2020 Reference: 25536

Mr Michael Naylor Company secretary Cygnus Gold Limited 45 Richardson Street WEST PERTH WA 6005

By email:

Dear Mr Naylor

Cygnus Gold Limited (‘CY5’): Appendix 3Y – Change of Director’s Interest Notice Query

ASX refers to the following:

1. CY5’s Appendices 3Y lodged on ASX Market Announcements Platform (‘MAP’) on 2 October 2020 for each of Michael Bohm, Lawrence Jackson, Raymond Shorrocks and Shaun Hardcastle (together the “Directors”) (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 each Director’s notifiable interest occurred on 22 September 2020. It appears that the Notice should have been lodged with ASX by 29 September 2020. Consequently, CY5 may have breached Listing Rules 3.19A and/or

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 Appendices 3Y were lodged late.

2. What arrangements does CY5 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 CY5 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 3:00 PM AWST Friday, 9 October 2020 . 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, CY5’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 CY5 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 CY5’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 CY5’s securities under Listing Rule 17.3.

Listing Rules 3.1 and 3.1A

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

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In responding to this letter, you should have regard to CY5’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 CY5’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

Elizabeth Harris

Manager, Listings Compliance (Perth)

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