A thing worth noting is that directors might be unable to...

A thing worth noting is that directors might be unable to participate in the capital raise without shareholders' approval. No such approval was sought.

Under ASX listing rule 7.2, offer of shares under a SPP can only be offered 'without' shareholders' approval under certain conditions, including the SPP offer price must be at least 80% of the volume weighted average market price (VWAP) of the company's shares over the last five days either before the day on which the issue was announced.

The share purchase plan booklet shows the VWAP over the relevant period was $0.10. This means the issue price of the SPP was priced at a 25% discount, exceeding the 80% threshold.


My discussion with the company is that it did sought exemption from ASX from this listing rule but this was not given. Hence, this could be the reason why no directors has participated in the capital raise.

Yes - the next follow up question would be if they cannot participate in the SPP, are there any impediments to them purchasing on market particularly given the prevailing share price is below the SPP issue price. This I don't know.