And that is a ' Winning ' observation Winner. In regards to the Massive Question as to Why the ASX had not raised this query up until now.
And it's not as if they had heaps of ' Prior Opportunity '. I mean they were the ones who raised the FIRST query in regards to the undisclosed Broker Options which were attached to their nothing untoward's $5,000 per month commercial Advisory Mandate. At the same time , they also raised the side issue query of Richards ' neutral ' shares and options trading. So why didn't they put TWO and TWO together then in regards ' the BOD's written approval ' for Richards which was claimed to have been received at the time.
Surely they knew this coincided with the meeting , the subsequent financials , and even to an extent the recently deferred proposed merger details via the Independent Experts Report. Remembering that was meant to be delivered to the market and shareholders in early February until it was changed.
And whilst the ASX recommends 5 certain criteria via it's own ' Guidance Note 27 ' in regards Individual Company's securities trading policies , there are no hard and fast rules in regards time frames associated with closed periods etc.
However , It does specify ' Written Approval ' is required . Especially when involving the Managing Director who would require the Chairman's written consent. It ( Guidance Note 27 ) talks about the relevancy of the policy with regards to potential price sensitive financial information ...etc , and requires a securities trading policy be issued to the ASX for its subsequent release to the Market.
Now I don't know about you all , but since meticulously following Cirralto and its announcements through the Corporate Restructure , the various shareholder meetings , the publication of its Governance Statement released on 30th October 2020 , it's revised Constitution on 11th February 2021 , and every other compliance announcement released on the ASX platform - I have yet to see the Securities Trading Policiy which the ASX should have had, or requested and made available to the Market and CRO's shareholders. And because it says so in its very own Guidance Note 27........
And Cirralto's Corporate Government Statement clearly says that they have one...... as indicated as follows :-
SHARE TRADING POLICY( per Governance Statement)
" The Company has a share trading policy that regulates the dealings by Directors, Officers and Consultants, in shares, options andother securities issued by the Company. The policy has been formulated to ensure that Directors, Officers, Employees andConsultants who work on a regular basis for the Company are aware of the legal restrictions on trading in Company securitieswhile in possession of unpublished price-sensitive information. "
So let's just assume for the moment that ASX is only doing this now because in some way they want to be seen to be exercising their own ' Jurisprudence ' with respect to its role in ' Caretaking ' and / or ' Safeguarding ' the small Mom & Dad and Newbie Investors..... Hell no ......couldn't be that right ?.......
But if it was , then why did they NOT raise this query as Winner has pointed out over 2 months or 60 - 75 days post the actual event taking place. And so why haven't we ALL seen this ASX's release to the Market of the Company's securities trading policy that they allegedly claim is their responsibility to release to the Market.
Have they even received it ? And if not , have they asked for it ? .....and if so , When did they ask for it from CRO's Company Secretary , Management , or Chairperson. Now , I know it's on their Website ......but when was it ' released to the Market ' ? Particularly in view of the fact that the Company is quite a different Company as result of the Financial Year 2020 balance sheet re-structure .....with many many more varied and different shareholders coming onboard with their Investment.
So in light of these changes , shouldn't we have sighted this policy more recently for the benefit and protection of ASX participant Investors. Especially at this end of the Market. I mean they ask for Cashflow Information on a Quarterly Basis. Surely Insider Director or KMP's warrant an annual or bi annual Market Update . And they do it with their Corporate Governance Appendix 4- G don't they ?
So folks , given this lengthy ' in between ' delay or period , it clearly looks like a trial by ' assassination '. In other words someone has raised this issue in retrospect to fulfilling some corporate vendetta or grievance. And I would say that in all likelihood it was that Sodapop fizz out .....that fraudulent defaming fellow who was threatening to contact ASIC etc....etc....
Interesting as well that a significant part of the Securities Trading Policy had been left out of some previous posts. Namely the section which pertains to some relevant ' Exclusions '........
Looks like they have in part complied with their own policy right ?
Interesting their policy also states quite clearly that the KMP's or otehr BOD members need consult and obtain the sign off from the Company Secretary in these sorts of Directors securities trading. Time to obtain a new Company Secretary I would think. This sort of oversight by the very person who is charged and being paid for these services is nothing short of unforgivable.
(20min delay)