Ann: December Quarter Update, page-35

This is what the ASX replied to my formal complaint:::


Realm Resources Limited (“RRP”)

ASX refers to your online report dated 11 January 2017 raising concerns about the suspension of trading in RRP’s shares.

ASX appreciates that you are concerned about your investment in RRP. As will be explained in this letter, RRP has been suspended as it has failed to comply with ASX policy in the application of the Listing Rules.

On 6 October 2016, RRP announced to the market that ASX had determined that the Foxleigh transaction constitutes a back door listing, and that RRP is required to re-comply with chapters 1 and 2 of the Listing Rules. The announcement also advised that the suspension of RRP’s shares would not be lifted until it had satisfied all of the re-compliance conditions.

ASX’s policies and procedures applying to these rules are documented in ASX Listing Rule Guidance Note 12 Significant Changes to Activities (“GN 12”).

On 2 November 2016 ASX released a consultation paper advising of a change in its policy about immediately suspending a listed entity that announces a back door listing transaction. ASX will now allow such an entity to resume trading (at least up to the date of the shareholder vote approving the back door listing) if it makes an announcement that contains all of the information referred to in proposed new Annexure A to GN 12 and ASX is otherwise satisfied that the announcement includes sufficient information about the transaction for trading in the entity’s securities to take place on a reasonably informed basis.

Accordingly, the onus is on RRP’s board to make an announcement that meets these requirements so that its securities may resume trading ahead of the shareholder resolution approving the Foxleigh transaction. If RRP does not make an announcement to ASX’s satisfaction, then RRP’s securities will remain suspended until its re-compliance with chapters 1 and 2 of the Listing Rules. To date, ASX is yet to receive from RRP any proposed announcement in order to satisfy the requirements of Annexure A of GN 12. RRP’s announcement dated 13 January 2017 indicates that it expects to provide further updates on the process and timetable for re-compliance in the near term.

ASX Compliance Pty Limited 20 Bridge Street www.asx.com.au ABN 26 087 780 489 Sydney NSW 2000 Customer service 13 12 79



Therefore, as it is RRP’s responsibility to comply with the above mentioned policy, any announcement or update regarding RRP will be prepared by the board of RRP and not by ASX. Further, ASX cannot force RRP to provide such an announcement except by way of continued suspension.

We hope this letter has helped to clarify the situation. Yours sincerely

[sent electronically without signature]

Stephanie So

Senior Adviser, Listings Compliance

P: 13 12 79