DEVELOP GLOBAL LIMITED — Regulatory Filings 2021

Apr 25, 2021

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26 April 2021

ASX Compliance Pty Limited Attention: Laura Gomme Level 40, Central Park 152-158 St George’s Tce PERTH WA 6000

via email: laura.gomme@asx.com.au

Dear Ms Gomme

PRICE AND VOLUME QUERY

In response to your letter dated 26 April 2021 regarding an increase in the Company’s share price and in the volume of trading in the securities, the Company’s response is as follows:

1. Is the Entity aware of any information concerning it that has not been announced which, if known, could be an explanation for recent trading in the securities of the Company?

Answer: No

1. Not Applicable.

2. If the answer to Question 1 is “no”, is there any other explanation that the Entity may have for the recent trading in its securities?

The Company notes that, as outlined in its ASX announcement of 15 April 2021, it recently commenced preparations for a geotechnical drilling programme which will be followed by an In-fill drilling programme to potentially upgrade the current Inferred Resources at the Sulphur Springs Copper-Zinc Project.

The Company also notes that a news article released by Mining News on Friday 23 April 2021 included comments from Ophir Asset Management senior portfolio manager Andrew Mitchell based on an interview with Bill Beament regarding Venturex. As announced on the 24 February 2021, Mr Beament will lead a recapitalisation of Venturex designed to set the Company up for growth as a supplier of new-generation energy and technology materials, subject to shareholder approval.

1. VXR confirms that it is in compliance with the listing rules and, in particular, Listing Rule 3.1.

2. These responses have been authorised for release by members of the Board of VRX.

Yours sincerely

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TREVOR HART Company Secretary

Registered & Principal Office ABN 28 122 180 205 Level 2, 91 Havelock Street, West Perth WA 6005 Tel: +61 8 6389 7400 www.venturexresources.com PO Box 585, West Perth WA 6872 Fax: +61 8 9463 7836 E: admin@venturexresources.com

VXR_ASX_PriceQuery_210426

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26 April 2021

Mr Trevor Hart Venturex Resources Limited Level 2, 91 Haverlock Street West Perth WA 6005

By email: trevor.hart@venturexresources.com

Dear Mr Hart

Venturex Resources Limited (‘VXR’): Price - Query

ASX refers to the following:

• A. The change in the price of VXR’s securities from an intraday low of $0.42 on 22 April 2921, to a high of $0.64 today, 26 April 2021; and

• B. The significant increase in the volume of VXR’s securities traded from 22 April 2021 to 26 April 2021.

Request for information

In light of this, ASX asks VXR to respond separately to each of the following questions and requests for information:

1. Is VXR 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”.

3. (a) Is VXR relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? Please note that the recent trading in VXR’s securities would suggest to ASX that such information may have ceased to be confidential and therefore VXR 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.

4. (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).

5. (c) If an announcement cannot be made immediately, why not and when is it expected that an announcement will be made?

6. If the answer to question 1 is “no”, is there any other explanation that VXR may have for the recent trading in its securities?

7. Please confirm that VXR is complying with the Listing Rules and, in particular, Listing Rule 3.1.

8. Please confirm that VXR’s responses to the questions above have been authorised and approved under its published continuous disclosure policy or otherwise by its board or an officer of VXR with delegated authority from the board to respond to ASX on disclosure matters.

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 5 PM AWST Monday, 26 April 2021 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

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

ASX Limited [[Listings]]

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within the exceptions mentioned in Listing Rule 3.1A, VXR’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 VXR 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, 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 VXR’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 VXR’s securities under Listing Rule 17.3.

Listing Rules 3.1 and 3.1A

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

Laura Gomme

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

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Listings Adviser, Listings Compliance (Perth)

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