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IMAGE RESOURCES NL Regulatory Filings 2015

Jan 14, 2015

65117_rns_2015-01-14_c35e7a40-eaa8-40a0-a101-02fa3b460a66.pdf

Regulatory Filings

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Suite 4a, 5 Mumford Place Balcatta WA 6021 PO Box 1075 Balcatta WA 6914 Telephone 08 9485 2410 Facsimile 08 9240 7845 www.imageres.com.au Image Resources NL ABN 57 063 977 579

15 January 2015

Mauro Piccini ASX Compliance Pty Ltd Level 40 Central Park 152 -158 St George’s Terrace Perth WA 6000

Email: [email protected]

Dear Mauro,

IMAGE RESOURCES NL (the “Company”)

We refer to the price and volume query from ASX Limited (“ASX”) of 14 January 2015 (“Correspondence”) to the Company.

We respond to the points raised in your correspondence (adopting the same numbering) as follows:

    1. The Company is not 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. As mentioned in the Company’s September Quarterly Activities Report, the Company is in early stage confidential discussions with a number of third parties with the intention of being able to bring the North Perth Basin Project into production as quickly and cost effectively as practicable. During the period since the date of release of the September Quarterly Activities report discussions have continued but the proposals have remained incomplete, confidential and negotiations are continuing.
    1. The discussions the Company is having with third parties are incomplete, subject to further negotiation, comprise matters of supposition and are insufficiently definite to warrant disclosure. The Company does not consider that an announcement is warranted. The Company confirms that it will make an announcement in line with its continuous disclosure obligations.
    1. The Company is not aware of any other explanation for the recent trading in its securities.
    1. The Company confirms that it is in compliance with the listing rules and in particular listing rule 3.1.

Please contact me if you have any further queries.

Regards

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Dennis Wilkins

Company Secretary

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ASX Compliance Pty Limited ABN 26 087 780 489 Level 40, Central Park 152-158 St Georges Terrace PERTH WA 6000

GPO Box D187 PERTH WA 6840

Telephone 61 8 9224 0000 www.asx.com.au

14 January 2015

Mr D Wilkins Company Secretary Image Resources NL Suite4a, 5 Mumfors Place BALCATTA WA 6021

Email: [email protected]

Dear Dennis

IMAGE RESOURCES NL (the “Company”)

PRICE AND VOLUME QUERY

We have noted a change in the price of the Entity’s securities from a close of $0.085 on 12 January 2015 to an intra day high at the time of writing of $0.10 today, 14 January 2015. We have also noted a significant increase in the volume of trading in the Entity’s securities over this period.

In light of the price change and increase in volume, ASX asks you to respond separately to each of the following questions:

  1. Is the Entity 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”:

    • a.Is the Entity relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1?

Please note that the recent trading in the Entity’s securities would suggest to ASX that such information may have ceased to be confidential and therefore the Entity 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.

  • 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).

  • c. If an announcement cannot be made immediately, why not and when is it expected that an announcemant will be made?
  1. 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?

  2. Please confirm that the Entity is in compliance with the Listing Rules and, in particular, Listing Rule 3.1.

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When and where to send your response

This request is made under, and in accordance with, Listing Rule 18.7. Your response is required as soon as reasonably possible and, in any event, by not later than 06:45 am WST tomorrow, 15 January 2015 . If we do not have your response by then, ASX will have no choice but to consider suspending trading in the Entity’s securities under Listing Rule 17.3.

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, the Entity’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.

ASX reserves the right to release a copy of this letter and your response on the ASX Market Announcements Platform under Listing Rule 18.7A. Accordingly, your response should be in a form suitable for release to the market.

Your response should be sent to me by e-mail at [email protected] and [email protected]. 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.

Listing Rule 3.1

Listing Rule 3.1 requires a listed entity to give ASX immediately any information concerning it that a reasonable person would expect to have a material effect on the price or value of the entity’s securities. Exceptions to this requirement are set out in Listing Rule 3.1A.

The obligation of the Entity to disclose information under Listing Rules 3.1 and 3.1A is not confined to, nor is it necessarily satisfied by, answering the questions set out in this letter.

In responding to this letter, you should have regard to the Entity’s obligations under Listing Rules 3.1 and 3.1A and also to Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 – 3.1B .

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 the Entity’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 may 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 .

If you have any queries or concerns about any of the above, please contact me immediately.

Yours sincerely

[Sent electronically without signature]

Mauro Piccini Senior Adviser, Listings Compliance (Perth)

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