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REDSTONE RESOURCES LIMITED — Director's Dealing 2015
Feb 4, 2015
65676_rns_2015-02-04_3526f2f0-2acd-4d49-b2d5-ced2f093e088.pdf
Director's Dealing
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5 February 2015
Sandra Wutete Adviser, Listings (Perth) ASX Compliance Pty Ltd
By email: Sandra. [email protected]
Dear Sandra
Redstone Resources Limited (the "Company")
In response to your letter dated 3 February 2015, regarding the late lodgement of an Appendix 3Y: Change of Directors' Interest Notice for Mr Edward van Heemst, Redstone Resources Limited responds as follows:
1. Please explain why the Appendix 3Y was lodged late
The Appendix 3Y was lodged late due to an administrative oversight by the Company following delayed mail communication of the 16 January 2015 trade, which related to an unfilled buy order from late December 2014.
It was upon review of the daily registry movement report for 21 January 2015 late on Friday 23 January 2015 that the Company became aware of the settled trade. Upon discovery of the trade oversight the Appendix 3Y was immediately lodged, being the next business day after 23 January 2015, the day the Appendix 3Y should have been lodged.
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
The Company has entered into Deeds of Notifiable Interests with all Directors, which requires them to notify details of any changes in interests in Company securities and contracts within 2 business days after the change has occurred. Furthermore, all Directors are aware that the Company has a Securities Trading Policy whereby following completion of proposed dealing in Company securities the Director must immediately provide confirmation to the Company Secretary that the dealing has occurred including details of the deal. Directors of the Company must notify the Company Secretary of any dealings in Redstone securities within 3 business days of the date of any such dealings in order to comply with the requirements of the Corporations Act and the ASX Listing Rules.
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
The requirement to notify the Company Secretary of any dealings in the Company's securities within 2 business days will be reinforced to allow for sufficient time for lodgement and to ensure the oversight does not recur. Further, it has requested that all trade contract notes now be emailed, rather than mailed, to Mr van Heemst to ensure that he is aware that a trade has occurred within the required 2 day time frame and can advise the Company accordingly.
However, apart from this administrative oversight, the Company considers the current arrangements to be adequate to ensure compliance with listing rule 3.19B.
Yours sincerely,
Miranda Conti Company Secretary

ASX Compliance Pty Limited ABN 26 087 780 489 Level 40 Central Park 152-158 St George's Terrace PERTH WA 6000
GPO Box D187 PERTH WA 6840
Telephone 61 8 9224 0000 Facsimile 61 8 9381 1322 www.asx.com.au
3 February 2015
Ms Miranda Conti Company Secretary Redstone Resources Limited 60 Havelock Street WEST PERTH WA 6005
By email: [email protected]
Dear Miranda
Redstone Resources Limited (the "Company")
We refer to the following:
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- The Company's announcement lodged with ASX Ltd ("ASX") on 27 January 2015 regarding a change of director's interest notice for Mr Edward van Heemst ("Appendix 3Y").
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- 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 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.
- 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 Meldrum's notifiable interest occurred on 16 January 2015 the Appendix 3Y should have been lodged with the ASX by 23 January 2015. As the Appendix 3Y was lodged on 27 January 2015 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.
-
- 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?
-
- 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]. It should UnotU be sent to the Company Announcements Office.
A response is requested as soon as possible and, in any event, not later than 3:00 pm WST on Friday, 6 February 2015.
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]
Sandra Wutete Senior Adviser, Listings Compliance (Perth)