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HAMMER METALS LIMITED Director's Dealing 2013

Jun 17, 2013

65065_rns_2013-06-17_d97bda63-390d-44bf-ab26-aa8cc00b39ed.pdf

Director's Dealing

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18 June 2013

Elizabeth Harris Principal Advisor Listings Compliance (Perth) Australian Securities Exchange Level 8, Exchange Plaza 2 The Esplanade Perth WA 6000 By email: [email protected]

Dear Ms Harris,

I refer to your letter dated 13 June 2013 in relation to a recently lodged Appendix 3Y – Change in Directors Interest Notice and to the queries ASX has raised.

ASX

Q1. Please explain why the Appendix 3Y was lodged later than the timeframe set out in listing rule 3.19A?

Late lodgement of the Appendix 3Y was an administrative oversight.

ASX

Q2. 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?

The Company has informed all Directors of the disclosure requirements set out in Listing Rule 3.19A. In addition the Company has previously adopted a governance policy on share trading which has been circulated to all Directors. This policy stipulates the need to consult with both the Managing Director and Company Secretary prior to and immediately after a trade in the Company’s securities is contemplated by a Board member or employee.

ASX

Q3. If the current arrangements are inadequate or are not being enforced, what additional steps does the Company intend to take to comply with listing rule 3.19B?

The Company believes the current arrangements are adequate and does not believe any additional steps are required.

Yours sincerely

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Mark Pitts 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

13 June 2013

Mr Mark Pitts Company Secretary Midas Resources Limited Level 1 282 Rokeby Road SUBIACO WA 6008

Dear Mark

Midas Resources Limited (“Company”)

We refer to the following:

  1. The Company’s announcement lodged with ASX Ltd (“ASX”) on 10 June 2013 regarding a change of director’s interest notice for Mr Geoff Balfe (“Appendix 3Y”);

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

  3. 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 an 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). The entity must complete an 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 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

  1. 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.

The Appendix 3Y indicates changes in Mr Balfe’s notifiable interest occurred on 28 May 2013 and 6 June 2013 so an Appendix 3Y should have been lodged with the ASX by 4 June 2013. As the Appendix 3Y was lodged on 10 June 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.

  1. Please explain why the Appendix 3Y was lodged late.

  2. 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. 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 3:00PM WST on Tuesday June 18 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

Elizabeth Harris rincipal Adviser, Listings Compliance (Perth)

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