Ann: Revised Corporate Governance Statement & Revised Appendix 4G, page-2

I place a lot of importance on Corporate Governance and these multiple revisions over the last 4 months cause me great concern. This further erodes my confidence in the Board because it looks like they have treated it as a box ticking exercise.

Corporate Governance Statement for the year ending 31 July 2019 has now had 3 amendments (29 Nov 2018, 13 Feb 2019 and 14 March 2019) to the original version dated 31 Oct 2018. So it took the Company Secretary and Board four times to get this one right!

Based on a quick review tonight, is everyone aware Havilah does not have: a Board skills matrix (recommendation 2.2); a Risk Management Policy nor completed a full risk assessment during the year ending 31 July 2018 (recommendation 7.2); or a Risk Management Strategy for material exposure to economic, environmental and social sustainability risks (recommendation 7.4)? All corporate governance infrastructure that should have been in place years ago.

Based on the original 2015, 2016, 2017 and 2018 Appendix 4G submitted to ASX, shareholders would have believed they had them in place.

Appendix 4G has now been submitted 3 times to ASX (31 Oct 2018, 13 Feb 2019 and 14 March 2019). The last two looks like they were to correct misleading information in the original version. So it took the Company Secretary and Board three times to get this one right!

The above is an absolute disgrace!

If this had happened at my company the person responsible would have been dismissed by now.

The Company Secretary and Board should have exercised a lot more care to ensure that the information in the 31 Oct 2018 and 13 Feb 2019 documents was actually accurate before submitting to ASX. I do hope they know, giving materially false or misleading information to ASX potentially breaches the Corporations Act and is an offence.

The numerous revisions to these Corporate Governance documents also cannot have helped the Board's credibility with the ASX.


"If you can't do the little things right, you will never do the big things right." - William H. McRaven

DYOR