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SUREFIRE RESOURCES NL — Director's Dealing 2010
Feb 9, 2010
65857_rns_2010-02-09_1cc1c979-a3be-4b2b-875f-ce6aa717df1c.pdf
Director's Dealing
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10 February 2010
Mr Peter Tranter Senior Adviser, Issuers (Perth) ASX Limited. Level 8 Exchange Plaza 2 The Esplanade PERTH WA 6000
By Fax: 9221 2020
Dear Peter.
ASX APPENDIX 3Y
I refer to your letter dated 9 February 2010 with regard to the ASX Appendix 3Y's for Angus Middleton lodged by the company on 25 January 2010 and 8 February 2010
With regard to your letter I advise as follows:
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- The Appendix 3Y's were lodged pursuant to a review initiated by the Company of its compliance with ASX Listing Rules 3.19A and 3.19B. The review identified the inadvertent omission of these Appendices. As soon as the error was identified, the Company and the Director concerned took immediate steps to correct the omission by the late lodgement of the relevant declarations.
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- Each Director of the Company has executed an Agreement with the Company that is substantially similar to Attachment 1 to Guidance Note 22 of the ASX Listing Rules. Each Director of the Company is committed to compliance with ASX Listing Rules 3.19A and 3.19B as well as all the ASX Listing Rules.
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- The Directors of the Company as a whole are committed to enforcement of the Agreements referred to above.
Yours sincerely,
David J. Semmens
COMPANY SECRETARY
ABN 48 083 274 024 1 Ulte 10, 281 Hay Street Sublaco 6008 Western Australia T +61 6 3981 6922 F -61 8 9381 6060 E [email protected]

NO.077 P.2/4
ASX Markets Supervision Ptv Ltd ABN 26 087 780 489 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
9 February 2010
Mr David Semmens Company Secretary Black Ridge Mining Limited Suite 10 281 Hay Street SUBIACO WA 6008
By Email: [email protected]
Dear David
Appendix 3Y- Change of Director's Interest Notice - Black Ridge Mining Ltd (the "Company")
We refer to:
- Each Appendix 3Y lodged by the Company with ASX Limited ("ASX") on 25 January 2010 and on 8 1. February 2010 for Angus Middleton:
- $2.$ 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.
- 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.
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). The entity must complete Appendix 3Y and give it to ASX no more than 5 business days after the change occurs.
- 3.19A3 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.
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- 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
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within the time period allowed by listing rule 3.19.A. The entity must enforce the arrangements with the director.
$\overline{4}$ . 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 lodged on 25 January 2010 for Angus Middleton indicated that:
- a change in the director's relevant interests occurred on 23 December 2009. It appears therefore that $(1)$ the Appendix 3Y should have been lodged with the ASX by 5 January 2010. As the Appendix 3Y was lodged on 25 January 2010, it appears that the Company may be in breach of listing rules 3.19A and/or 3.19B. It also appears that there may have been a breach of S205G of the Corporations Act by the director concerned.
- $(2)$ a change in the director's relevant interests occurred on 30 June 2009. It appears therefore that the Appendix 3Y should have been lodged with the ASX by 7 July 2009. As the Appendix 3Y was lodged on 25 January 2010, it appears that the Company may be in breach of listing rules 3.19A and/or 3.19B. It also appears that there may have been a breach of S205G of the Corporations Act by the director concerned.
The Appendix 3Y lodged on 8 February 2010 for Angus Middleton indicated that:
- a change in the director's relevant interests occurred on 30 December 2009. It appears therefore that $(1)$ the Appendix 3Y should have been lodged with the ASX by 5 January 2010. As the Appendix 3Y was lodged on 8 February 2010, it appears that the Company may be in breach of listing rules 3.19A and/or 3.19B. It also appears that there may have been a breach of S205G of the Corporations Act by the director concerned.
- $(2)$ a change in the director's relevant interests occurred on 20 January 2010. It appears therefore that the Appendix 3Y should have been lodged with the ASX by 28 January 2010. As the Appendix 3Y was lodged on 8 February 2010, it appears that the Company may be in breach of listing rules 3.19A and/or 3.19B. It also appears that there may have been a breach of S205G of the Corporations Act by the director concerned.
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:
- $\mathbf{1}$ . Please explain why each 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?
- 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 facsimile on facsimile number (08) 9221 2020. It should not be sent to the Company Announcements Office.
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A response is requested as soon as possible and, in any event, not later than half an hour before the start of trading (i.e. before 6.30 a.m. W.S.T.) on Thursday, 11 February 2010.
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 should separately address each of the questions asked. If you have any queries or concerns, please contact me immediately
Yours sincerely,
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Peter Tranter Senior Adviser, Issuers (Perth)
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