Sarama Resources Ltd. — Director's Dealing 2024

Jan 23, 2024

24 January 2024

ASX Market Announcements ASX Securities Exchange Limited 20 Bridge Street Sydney NSW 2000

Attention: Nicola Mullen - Adviser, Listings Compliance (Perth)

Appendix 3Y's – Change of Director's Interest Notice Query

Sarama Resources Ltd (ASX: SRR) refers to your letter dated 23 January 2024.

SRR responds to your request for information as follows:

• 1. SRR notes that the Appendix 3Y's Change of Director's Interest Notices lodged on 23 January 2023 for Messrs Andrew Dinning, Simon Jackson, Adrian Byass, and Steven Zaninovich were lodged 1 business day later than required under ASX Listing Rule 3.19A.2. SRR confirms that the late lodgement was only due to an administrative oversight following the expiry of options. As soon as the oversight was identified the documents were lodged with the ASX.
• 1. SRR confirms it has agreements in place with its directors in compliance with ASX Listing Rule 3.19B and confirms that its current arrangements are adequate to ensure it meets its disclosure obligations under ASX Listing Rule 3.19A.
• 1. SRR considers the late lodgement as an isolated administrative oversight. SRR believes that its current practices are adequate to ensure compliance with ASX Listing Rules.

This letter has been approved and authorised for release by SRR's Board of Directors.

Yours sincerely

Luigi Evangelista Company Secretary Sarama Resources Ltd

Copy : ListingsCompliancePerth@asx.com.au.

23 January 2024

Mr Luigi Evangelista Company Secretary

By Email: levangelista@saramaresources.com

Dear Mr Evangelista

Sarama Resources Ltd ('SRR'): Appendix 3Y's – Change of Director's Interest Notice Query

ASX refers to the following:

• 1. SRR's 4 Appendix 3Y's lodged on the ASX Market Announcements Platform ('MAP') on 23 January 2024 for:
• 1.1 Mr Andrew Dinning;
• 1.2 Mr Simon Jackson;
• 1.3 Mr Adrian Byass; and
• 1.4 Mr Steven Zaninovich.

(the 'Notices');

• 1. 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 Mr Dinnings, Mr Jackson, Mr Byass and Mr Zaninovich's notifiable interest occurred on 15 January 2024. It appears that the Notice should have been lodged with ASX by 22 January 2024. Consequently, SRR may have breached Listing Rules 3.19A and/or 3.19B.

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 Appendix 3Y's were lodged late.
• 1. What arrangements does SRR 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?
• 1. If the current arrangements are inadequate or not being enforced, what additional steps does SRR 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 Monday, 29 January 2024. 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, SRR'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 SRR 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 SRR'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 SRR's securities under Listing Rule 17.3.

Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to SRR'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 SRR'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

ASX reserves the right to release all or any part of this letter, your reply and any other related correspondence between us to the market under Listing Rule 18.7A.

Yours sincerely

ASX Compliance