Ann: Application for quotation of securities - AEV, page-32

Correct. The ASX Listing Rules moves the burden of responsibility on to the listed entity (in this case Avenira Ltd) and the listed entity is then required to set out the policy as they deem appropriate in their policies as you have highlighted.

You have highlighted that Avenira in its policies document has defined the following:
1. Section 3 (a) does actually define a blackout period for Period Disclosures although it doesnt use the word "blackout".
2. Section 3 (c) actually sets a rule for trading within a period before a Continuous Disclosure is made to the market. One might argue that the Chair has actually breached this by converting when an unscheduled announcement in regards FEED and Mine and Mine Management is due and he may or may not be aware of its contents but would be well aware of the need to inform the market of its pending results.

An interesting conundrum to contemplate. Here is the test:
"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 ASX that information."

Also as a side note I did pick up the Avenira Corporate Governance and Policy Document was last updated and approved by the Board in September 2015 (and the actual document was last saved in September 2016) which indicates they actually are in breach of their own Governance Statement disclosure to the ASX each year thereafter. This is the responsibility of the Company Secretary.