Since 10 March 2025, I’ve formally requested a full copy of the CHM shareregister under Section 173 of the Corporations Act 2001 (Cth). To date, theCompany has failed to comply. Despite being legally obliged to provide theregister in full digital format, Chimeric has only issued a partial hard copyand has refused to include shareholder email addresses in the full register request.
This is inconsistent with Corporations Regulations 2C.1.02, whichrequire the register to be provided in a format that allows data extraction(i.e. CSV or delimited format) and copied onto a CD-ROM or USB portable memory device. Theirrefusal to include email addresses contradicts Lawrence v Melbourne FootballClub Ltd [2022] VSC 658, which confirmed that if a shareholder has nominatedemail as their communication method, then their email address forms part oftheir “address” in the register.
I'm now considering applying to the Federal Court to compel disclosureunder Section 247A of the Corporations Act. The application fee is $1,695.
Before applying to the Court, I want to gauge shareholder support viathis forum. If there’s clear shareholder consensus and support for change, I’llproceed with the court application and begin contacting fellow shareholdersregarding potential changes to the Board.
The seriousness of this situation is highlighted in the summary table ofalleged breaches I compiled, including potential violations of:
- Sections 173, 180, 181, 182, 183, 674 of the Corporations Act;
- ASX Listing Rule 3.1.
The lack of transparency, potential market misconduct, and consistentunderperformance have already eroded investor confidence. The limitedparticipation in recent capital raises — both from sophisticated investors andretail holders — suggests deep concern.
If shareholders remain passive, Chimeric may follow the same pattern asother companies tied to Paul Hopper, where shareholder value has been destroyeddue to poor governance and a lack of accountability.
Let me know your thoughts please.
| Provision Breached | Description | Example of Conduct |
|---|
| 1 | s.173 | Failure to properly maintain and provide access to the share register | Refusing full digital register; omitting email addresses despite Lawrence v Melbourne Football Club precedent |
|---|
| 2 | s.180 | Duty of care and diligence | Selective trial disclosures during capital raises without transparency |
|---|
| 3 | s.181 | Duty to act in good faith | Suppressing trial data before raises |
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| 4 | s.182 | Improper use of position | Participating in raises potentially while holding inside information |
|---|
| 5 | s.183 | Improper use of information | Using undisclosed data to time personal or insider investments |
|---|
| 6 | s.674 | Continuous disclosure obligations | Failing to release CORE-NK trial efficacy updates |
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| 7 | ASX LR 3.1 | Failure to disclose price-sensitive info immediately | Delaying disclosures until a future event like ASH Conference |
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| 8 | s.1041H | Misleading or deceptive conduct | Omitting key facts in materials issued during capital raises (amongst other examples) |
|---|
| 9 | s.1308 | False/misleading statements in official docs | Misleading investor updates or trial news |
|---|
| 10 | ASX LR 3.19B | Failure to disclose director interests properly | Potential nondisclosure of holdings/trades around undisclosed news |
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| 11 | ASX LR 3.20 | Failure to disclose changes to the share register | Refusing digital access and obscuring shareholder communication |
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| 12 | ASX LR 3.17 | Inhibiting fair communication with shareholders | Withholding register access to prevent shareholder interaction |
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| 13 | ASX CG Principles (5 & 7) | Governance and risk management failures | Withholding material risk-related data from the market |
|---|
| 14 | Common Law Fiduciary Duty | Prioritising insider interests over shareholder fairness | Selectively informing insiders before capital market activities |
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The table outlines concerns and potential breaches of the Corporations Act 2001 (Cth) and ASX Listing Rules as they relate to Chimeric Therapeutics (ASX:CHM), based on publicly available information, market disclosures, and shareholder observations. These matters represent allegations and concerns only and should not be interpreted as conclusive findings of misconduct or legal liability. Any legal determinations are for the relevant regulators or courts to make.This document has been prepared in good faith by a shareholder for the purpose of promoting corporate transparency, accountability, and regulatory compliance. Readers are encouraged to conduct their own due diligence or seek independent legal advice before forming any conclusions.
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