Wolfpack?, page-120

WOLF PETROLEUM LTD ACN 116 249 060 and CHINA SAM ENTERPRISE GROUP CO LTD

We refer to your report of misconduct dated 18 November 2020. You raised concerns that the directors of Wolf Petroleum Ltd are attempting to liquidate the company in order to procure its assets. You allege that Wolf Petroleum Ltd’s Chinese strategic partner, China Sam Enterprise Group Co Ltd managed to secure one of the largest unmined oil deposits in Mongolia by holding 51% shares in Wolf Petroleum Ltd and then prevented Wolf Petroleum Ltd from receiving funding. You are concerned that the directors are facilitating or engaged in phoenix activity.

This correspondence is a follow up to an email sent to you by my colleague Genny Fagan on 22 December 2020. We apologise for the delay in responding.

Thank you for bringing this matter to ASIC's attention.

ASIC’s consideration of your concerns

ASIC has considered the information and documents you provided and we have conducted our own confidential enquiries. After careful consideration, ASIC has determined not to take any further action in relation to your concerns at this time.

ASIC assesses every report of misconduct we receive, in order to ascertain whether there has been conduct in contravention of the legislation that we administer. ASIC does not act on behalf of individuals, but we must consider whether the available evidence is sufficient as the basis for civil or criminal proceedings. We also consider whether any further action would have any regulatory impact by deterring similar conduct or provide a suitable remedy for the conduct in question.

ASIC is not automatically obliged to investigate every matter and we exercise our discretion when to do so. Further information regarding ASIC's policy in this regard is available in "Information Sheet 151: ASIC's approach to enforcement". This document is available from ASIC's website at www.asic.gov.au

ASIC and illegal phoenix activity

Generally, ASIC does not act on behalf of individuals to help them recover lost money, including money lost as the result of illegal phoenix activity. We rely on liquidators to provide us with reports about illegal phoenix activity so, if there is a liquidator involved, you should contact the liquidator first.

ASIC has published helpful guides about Illegal phoenix activity and Information Sheet 212 Illegal phoenix activity which explains what you can do if you are concerned about potential phoenix activity. This useful guide outlines some of the options you should pursue to resolve your dispute.

We have recorded the information you have provided in our confidential internal database.

Thank you again for making your concerns known to ASIC.

You should not expect ASIC to contact you again in relation to this report.

Yours sincerely