Scott, They needed to wait at least 12 months from the last SPP,...

Scott,

They needed to wait at least 12 months from the last SPP, under ASIC Class Order 09/425. Otherwise, they would have been required to prepare a Prospectus (which is a lot of extra work and extra costs).

Relevant extracts from the current SPP follow:

"This document is not a prospectus."

"This is an Offer Booklet for an offer of continuously quoted securities (as defined in the Corporations Act) of Havilah and has been prepared in accordance with ASIC Class Order 09/425 and the Corporations Act. In broad terms, ASIC Class Order 09/425 relates to share purchase plan offers that do not require the provision of a prospectus or other disclosure document."

"The SPP Offer is being made pursuant to ASIC Class Order 09/425. One of the conditions of that ASIC Class Order is that the SPP Offer must comply with the prescribed subscription limit, which means Eligible Shareholders may only acquire a maximum of $15,000 worth of Shares under a SPP or similar arrangement in any 12-month period.

Havilah has not undertaken any other SPP in the previous 12-month period."

Cheers

These are only my random thoughts and it does not constitute investment advice. DYOResearch.