Does not warrant suspension

(sent 09/09/15)

Dear ASX,

I refer to the securities of Antares Energy Limited (AZZ) and the ASX announcement ‘Purchase & Sale Agreements Northern Star & Big Star’ released on 07 September 2015.

Pursuant to Listing Rule 3.1 Continuous Disclosure, AZZ should be obligated to provide the following additional information to the market as part of its continuous disclosure requirements.

• What AZZ’s net working interest in the Northern Star and Big Star projects is (to which the consideration would be pro-rated).
• Any material defeating conditions relating to the Purchase and Sale Agreements.
• Whether consideration is expected to be cash.

The announcement released states ‘the Directors are pleased to advise the execution of the two independent Purchase and Sale Agreements’. As such, given that these Purchase and Sale agreements have been executed, it is imperative that the above information is released to the market to avoid a false market (especially given the significant volume on the date of this announcement). The above terms are material to the share price of AZZ and should have been released within this announcement to avoid speculation.

Please find attached completed ASX Complaint Form.

Please feel free to contact me should you have any queries or wish to discuss.

Thanks
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(sent 15/09/15)

Dear ASX,

I refer to the email below and the subsequent announcement ‘SUSPENSION FROM OFFICIAL QUOTATION’ released to the market on 15/09/15 by the ASX.

1. Pursuant to ASX Listing Rule 3.1, ‘once an entity is or becomes aware of any information concerning it that a reasonable person would expect to have a material effect on the price or value of the entity’s securities, the entity must immediately tell the ASX that information’.
   Information in relation to continuous disclosure is defined by CORPORATIONS ACT 2001, Section 674 (2): ‘is information that a reasonable person would expect, if it were generally available, to have a material effect on the price or value of ED securities of the entity’
   AZZ has since released to the market on 10/09/15 that:
   • the consideration relating to the purchase and sale agreements is for cash; and
   • the transaction is not subject to any conditions precedent.

The name of the Purchaser purchasing the assets is only a material term to the extent that a reasonable person would be able to conduct due diligence on the Purchaser’s ability to make the cash payments. However, given that the announcement (‘Purchase & Sale Agreements Northern Star & Big Star’ released on 07 September 2015) states that the Purchaser is a Private Equity purchaser, a reasonable person is unlikely to be able to gather any financial information in relation to the Purchaser and as such a reasonable person would not expect the name of the Purchaser to have a material effect on the price or value of the Entity’s securities.

1. ASX Guidance Note 8 is in relation to ASX Listing Rule 3.1-3.1B and is subject to the interpretation of ‘information’ as per the CORPORATIONS ACT 2001, Section 674 (2) – see point 1 above. Furthermore, section 4.15 states:
   ‘Wherever possible, an announcement under Listing Rule 3.1 should contain sufficient detail for investors or their professional advisers to understand its ramifications and to assess its impact on the price or value of the entity’s securities. For example, depending on the circumstances, an announcement about the signing of a contract relating to a significant acquisition or disposal might include information about the parties to the contract;….’
   For the reasons stated above (refer to point 1) the name of the Purchaser is not relevant in assessing the impact on the price or value of AZZ’s securities and is unlikely to have a material effect on the price or value of the Entity’s securities as it a Private Equity Purchaser (and access to its financials would be severely limited).

I believe the announcement (‘Northern Star & Big Star Sale – Update’, released 10/09/15) has provided a reasonable person with sufficient information to assess the impact that the purchase and sale agreements would have on the price or value of the AZZ’s securities pursuant to its continuous disclosure obligations as per ASX Listing Rule 3.1. and the Corporations Act 2001. Furthermore, the omission of the name of the Purchaser is not in contravention to ASX Listing Rule 3.1. as a reasonable person would not expect the inclusion of it to have a material effect on the price of AZZ’s securities as they would be no better or worse off with this information.

Please feel free to contact me should you have any queries or wish to discuss.

Thanks