I emailed ASX in Feb re decline in share price between Oct at $3...

I emailed ASX in Feb re decline in share price between Oct at $3 to $1.14 ........extract of their blurb


In relation to the first matter you have raised, ASX is of the view that the decline in SMN’s share price is due to the ordinary operation of the market and is not indicative of misconduct. In presenting this conclusion it is important to properly contextualize ASX’s role. ASX is not a corporate regulator that investigates and prosecutes market misconduct such as manipulative and insider trading. As a licensed market operator, ASX monitors and enforces listed entities’ compliance with its listing rules and actively ensures that trading in listed securities takes place in a fair, orderly and transparent market. Further information about ASX’s regulatory obligations is available on our website at:

http://www.asx.com.au/regulation/asx-regulatory-compliance.htm

In carrying out these obligations ASX’s Surveillance Group monitors trading on a real time basis (including access to information about the parties to, and details of, trades being conducted) to identify any trading which is indicative of an uninformed market and which may raise continuous disclosure concerns. ASX will generally issue a price query letter when it detects trading in a listed entity’s securities that cannot be explained by recent disclosures or market conditions. In this case, ASX has not seen sufficient cause to issue a query letter in the period to which you refer.

It is important to understand that there are various factors which affect an entity’s share price, including those which are specific to an entity, its operations and financial state, along with external factors such as macroeconomic and socio-political conditions, and market sentiment, trends and volatility, which are not under the control of the entity but which may directly affect the performance and/or investor perception of the entity. The duration of the impact of these factors varies, encompassing any timespan from immediate
to very long term. Whilst some of these factors fall within the continuous disclosure obligations imposed on listed entities by listing rule 3.1 (continuous disclosure), there are others that do not. ASX is currently satisfied that trading in SMN’s shares or other circumstances does not suggest that it is not in compliance with listing rule 3.1.