Please find below responses to the questions posed in your...

Please find below responses to the questions posed in your letter dated 7 August 2008.
Question 1. Is the company aware of any information concerning it that has not been
announced which, if known, could be an explanation for recent tranding in the securities of
the company.
No
Question 2. If the answer to Question 1 is yes, can an announcement be made
immediately? If not, why not and when it is expected that an announcement will be made?
While the answer to Question 1 is no, a relevant announcement was made shortly before to
the receipt of your letter yesterday.
Question 3. Is there any other explanation that the company may have for the price change
in the securities in the Company?
The company believes that the primary reason for the change in share price over the past 24
hours is the departure of the ANZ Banking Group from the Solagran share register. The
reason that the company holds this view is as follows.
During the first half of calendar year 2007, Solagran’s closing share price rose from 35c to a
peak of $1.50 on 15 May. The company believes that this increase was related to the
expectation that Ropren® was about to receive Ministry of Health approval in Russia as a
new pharmaceutical of natural origin. That approval was received and announced to the
market on 18 July. The share price rose to $1.55 that day and closed at $1.48.
Over the subsequent eight months during which the final steps involved in releasing Ropren®
for sale on the Russian market were completed by the various regulatory bodies, there were
two downward market corrections. The first was in August 2007 after which Solagran’s
share price settled into a trading range between $1.00 and $1.20. The second was in
January 2008 after which the share price settled into a trading range between 80c and
$1.00.
2
On 19 March 2008, Solagran announced that the Russian Ministry of Health had released
Ropren® for sale on the Russian market. The Solagran share price closed at $1.07 that day.
However one week later, the ANZ Bank appointed receivers to Opes Prime Stockbroking
Limited (Opes Prime) and in the process, ANZ claimed equity in some 65 million Solagran
securities which they announced would be sold on market as soon as possible. The effect of
this on the Solagran share price was immediate and obvious.
The Directors believe that the primary reason for the fall in the Solagran share price over the
past four months has been the market overhang created by the securities seized by ANZ.
That market overhang has now been removed.
Solagran received confirmation from ANZ that it had sold the last of the Solagran securities it
had seized at 11.30am on 7 August 2008. Solagran made an announcement to that effect
soon afterwards.
Question 4. Please confirm that the company is in compliance with the listing rules and, in
particular, listing rule 3.1.
The Directors confirm that the Company is in compliance with the listing rules including listing
rule 3.1.
Yours sincerely
Denis Kilroy
Executive Director
7 August 2008
Mr Dennis Zilberman
Solagran Limited
Level 11, 492 St Kilda Road
Melbourne VIC 3004
By e-mail only
Dear Dennis
Solagran Limited (the “Company”)
We have noted a change in the price of the Company’s securities from 29 cents at the start of trading today to a
high of 41 cents as at the time of writing. We have also noted an increase in the volume of trading in the
securities over this period.
In light of the price change and increase in volume, please respond to each of the following questions.
1. Is the Company aware of any information concerning it that has not been announced which, if known,
could be an explanation for recent trading in the securities of the Company?
2. If the answer to question 1 is yes, can an announcement be made immediately? If not, why not and
when is it expected that an announcement will be made?
Please note, if the answer to question 1 is yes and an announcement cannot be made immediately,
you need to contact us to discuss this and you need to consider a trading halt (see below).
3. Is there any other explanation that the Company may have for the price change in the securities of the
Company?
4. Please confirm that the Company is in compliance with the listing rules and, in particular, listing rule
3.1.
Your response should be sent to me by return email or by facsimile on (03) 9614 0303. It should not be sent to
the Company Announcements Office.
Unless the information is required immediately under listing rule 3.1, a response is requested as soon as
possible and, in any event, not later than half an hour before the start of trading (ie before 9.30 a.m. AEST) on
Friday 8 August 2008.
ASX Limited
ABN 98 008 624 691
Level 45
South Tower Rialto
525 Collins Street
Melbourne VIC 3000
GPO Box 1784
Melbourne VIC 3001
Telephone 61 3 9617 8656
Facsimile 61 3 9614 0303
www.asx.com.au
Under listing rule 18.7A, a copy of this query and your response will be released to the market, so your
response should be in a suitable form and separately address each of the questions asked. If you have any
queries or concerns, please contact me immediately.
Listing rule 3.1
Listing rule 3.1 requires an entity to give ASX immediately any information concerning it that a reasonable
person would expect to have a material effect on the price or value of the entity’s securities. The exceptions to
this requirement are set out in listing rule 3.1A.
In responding to this letter you should consult listing rule 3.1 and Guidance Note 8 – Continuous Disclosure:
listing rule 3.1.
If the information requested by this letter is information required to be given to ASX under listing rule 3.1 your
obligation is to disclose the information immediately.
Your responsibility under listing rule 3.1 is not confined to, or necessarily satisfied by, answering the questions
set out in this letter.
Trading halt
If you are unable to respond by the time requested, or if the answer to question 1 is yes and an announcement
cannot be made immediately, you should consider a request for a trading halt in the Company’s securities. As
set out in listing rule 17.1 and Guidance Note 16 – Trading Halts we may grant a trading halt at your request.
We may require the request to be in writing. We are not required to act on your request. You must tell us each
of the following.
• The reasons for the trading halt.
• How long you want the trading halt to last.
• The event you expect to happen that will end the trading halt.
• That you are not aware of any reason why the trading halt should not be granted.
• Any other information necessary to inform the market about the trading halt, or that we ask for.
The trading halt cannot extend past the commencement of normal trading on the second day after the day on
which it is granted. If a trading halt is requested and granted and you are still unable to reply to this letter
before the commencement of trading, suspension from quotation would normally be imposed by us from the
commencement of trading if not previously requested by you. The same applies if you have requested a
trading halt because you are unable to release information to the market, and are still unable to do so before
the commencement of trading.
If you have any queries regarding any of the above, please let me know.
Yours sincerely
Darren Collins
Senior Adviser, Issuers (Melbourne)