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SPRINTEX LIMITED — Director's Dealing 2016
Oct 6, 2016
65799_rns_2016-10-06_a8351d4a-83cd-433e-b4d1-2bdc98ab4b0d.pdf
Director's Dealing
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SPRINTEX LIMITED ABN: 38 106 337 599
ASX Code: SIX
6 October 2016
Mr. Jeremy Newman Senior Adviser, ASX Listings Compliance (Perth) ASX Limited Level 40, Central Park 152 – 158 St Georges Terrace PERTH WA 6000
By email: [email protected]
Dear Jeremy
We refer to the letter dated 3 October 2016 concerning the change in director’s interest notice for Mr Michael Wilson lodged on 22 September 2016 (“ Appendix 3Y ”).
We respond as to the questions raised by ASX as follows.
1. Please explain why the Appendix 3Y was lodged late
The 3Y was lodged late due to an administrative oversight by the Company. During the relevant period management of the Company was heavily engaged in finalisation of the Company’s financial statements for the period ending 30 June 2016. Upon realisation of the oversight, the 3Y was lodged the same day. Mr Wilson was not involved in the oversight and did not fail to pass on information of a change in shareholding.
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 arrangements in place with its directors to ensure that it is able to meet its disclosure obligations under ASX LR 3.19A. Prior to appointment, each director is provided with an employment contract/letter of appointment under which they agree to provide the Company with required information as soon as reasonably possible so the Company can meet its disclosure obligations.
The Company has a share trading policy which details the processes the directors must comply with in relation to share trading. The procedure for preparing the annual report includes confirmation by directors of the number of shares held directly and indirectly by them. Directors are reminded from time to time of their reporting obligations at Board meetings. Mr Wilson provided all appropriate information and complied – it was an internal oversight to not notify ASX.
3. If the current arrangements are adequate or not being enforced, what additional steps does the Company intend to take to ensure compliance with Listing Rule 3.19B?
The Company considers the procedures in place are adequate to enable compliance with Listing Rules.
Please contact the undersigned if you have any further questions.
Yours sincerely
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Robert Molkenthin Company Secretary
183 Mulgul Road, Malaga WA 6090 PO Box 3348 Malaga DC WA 6945 Phone: +61 8 9262 7277 Fax: +61 8 9262 7288 Email: [email protected] URL: www.sprintex.com.au
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3 October 2016
Mr Robert Molkenthin Company Secretary Sprintex Limited
Dear Mr Molkenthin
Sprintex Limited (the “Company”)
I refer to the following:
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The Company’s announcement lodged with ASX Ltd (“ASX”) on 22 September 2016 and released on 23 September 2016, regarding a change of director’s interest notice for Mr Michael Wilson (“Appendix 3Y”).
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Listing rule 3.19A which requires an entity to tell ASX the following:
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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:
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On the date that the entity is admitted to the official list.
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On the date that a director is appointed.
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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.
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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 an Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.
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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.
Level 40, Central Park 152-158 St Georges Tce Perth WA 6000
ASX Compliance Pty Ltd ABN 26 087 780 489
www.asx.com.au Customer service 13 12 79
- 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.
As the Appendix 3Y indicates a change in the Mr Wilson’s notifiable interests occurred on 9 September 2016, the Appendix 3Y should have been lodged with the ASX by 16 September 2016. As the Appendix 3Y was lodged on 22 September 2016, 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.
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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?
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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 not 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 Thursday, 6 October 2016 .
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]
Jeremy Newman
Senior Adviser, Listings Compliance (Perth)
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