Helping Biotron to Do Better and Deliver Tangible Results: Shareholders Call for ASIC Action and Regulatory Scrutiny

To: Australian Securities and Investments Commission (ASIC)
Subject: Urgent Request for Regulatory Review and Oversight of Biotron Limited (BIT)

Dear ASIC,

We, as concerned shareholders of Biotron Limited (ASX: BIT), are writing to formally raise serious concerns regarding the company’s governance, financial transparency, and use of shareholder funds.

Over the past several years, BIT has failed to deliver any meaningful progress or material updates regarding its commercialisation efforts, despite repeatedly raising capital. Most recently, the company raised funds under the pretext of progressing its partnership with C14, a process that remains opaque, undefined, and without measurable milestones. Since the announcement of the C14 engagement in November 2024, there has been silence from both BIT and C14 regarding the actual work conducted, progress made, or outcomes expected.

Despite this lack of transparency and performance, BIT continues to pay executive salaries — including to the CEO — with no public accountability, no visible effort toward commercial outcomes, and no clear justification for the ongoing cash burn. Shareholders are now questioning whether the funds raised are being used to support the personal lifestyles of executives, rather than advancing the company's core objectives.

We are particularly concerned that:

• There is no clear breakdown of how the recently raised funds have been or will be spent.

• BIT has not disclosed the terms of its engagement with C14, including deliverables, deadlines, or financial commitments.

• The company has not updated the market with any substantial or verifiable progress toward commercialisation.

• Executive compensation continues without performance-based justification.

• Shareholders are being misled or kept in the dark regarding the company’s actual direction and financial management.

In light of these concerns, we are calling on ASIC to urgently investigate and scrutinise:

1. Whether shareholder funds are being used in accordance with directors’ legal obligations under the Corporations Act.

2. Whether there has been any breach of continuous disclosure obligations under ASX Listing Rules.

3. Whether the BIT Board and executive management are fulfilling their fiduciary duties to shareholders.

4. The true nature of C14’s involvement, and whether the relationship is genuine and properly disclosed.

We believe it is the responsibility of ASIC to ensure that listed companies line Biotron operate transparently, ethically, and in alignment with shareholder interests. When companies like Biotron repeatedly raise money and fail to deliver, it undermines market confidence and leaves investors vulnerable to mismanagement and potential misconduct.

Shareholders are sending an SOS to ASIC. We respectfully request a formal review of Biotron Limited and appropriate regulatory action if breaches or misconduct are identified.

Yours sincerely,
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