ASX/ASIC

That is fantastic work - I would give you more thumbs up if I could. I know some shareholders will not see it this way, but the amount of effort you've put in on behalf of us all (and yourself, of course) is greatly appreciated.

I do not know enough about corporate regulations, or the extent of GMC's obligation to cooperate with a formal request from ASIC (or ASX), but there are a number of questions in there I can see them desperately wanting to avoid, as the answers could be quite damaging/embarrassing to management. All the more reason to know what they're hiding.

This is what I received from the ASX the second reply from them.



Gulf Manganese Corporation Limited (“GMC”)
ASX refers to previous correspondence in this matter, most recent of which was your email dated 1 February
2017 raising your concerns:
(a) that ASX had “vetted the investor and the market was given the impression that he had the ability to
pay”;
(b) that “ASX needs to address the continuous disclosure obligations of the GMC management”; and
(c) that GMC’s share price “increased dramatically” in the lead up to the trading halt in December.
In relation to paragraph (a) above, it is important to emphasise that it is not ASX’s role to “vet” the business
decisions of the board and management of a listed entity or to conduct any due diligence on the parties with
whom they transact business. To that end, ASX did not “vet” the investor, Mr Pak Marthen.
ASX’s role is to monitor and enforce compliance by a listed entity with the ASX Listing Rules. In this regard,
ASX refers to the announcement entitled “Response to ASX Query” lodged by GMC on the ASX Market
Announcements Platform on 15 August 2016, available online at:
http://www.asx.com.au/asx/statistics/displayAnnouncement.do?display=pdf&idsId=01767150)
This announcement discloses the specific queries raised by ASX in relation to this matter and GMC’s
responses. This includes queries about the due diligence enquiries GMC undertook on the financial and other
capacity of Pak Marthen to perform his obligations and whether GMC was in compliance with its continuous
disclosure obligations under the Listing Rules.
ASX also refers to the announcement entitled “Response to ASX Aware Letter” lodged by GMC on the ASX
Market Announcements Platform on 16 February 2017, available online at:
http://www.asx.com.au/asx/statistics/displayAnnouncement.do?display=pdf&idsId=01829152
This includes further enquiries by ASX relevant to the matters you have raised and GMC’s response.
Accordingly, in relation to paragraph (b) above, ASX considers that it has made appropriate enquiries and
taken appropriate action to address the continuous disclosure obligations of GMC’s management

ASX would also draw to your attention the announcement entitled “Termination of Binding Agreement”
lodged by GMC on the ASX Market Announcements Platform on 20 February 2017, available online at:
http://www.asx.com.au/asx/statistics/displayAnnouncement.do?display=pdf&idsId=01830010
which states that GMC has now terminated the agreement with Mr Pak Marthen and that GMC requests that
its voluntary suspension remain in place until alternative funding has been finalised and secured.
In relation to paragraph (c) above, ASX would note that GMC’s shares closed at $0.04 on 8 December 2016
and the last sale prior to the trading halt on 9 December 2016 occurred at $0.043, indicating only a 7.5%
increase in GMC’s share price in the immediate lead-up to the trading halt. ASX’s Surveillance Group uses
sophisticated computer systems to monitor trading on a real time basis to identify any abnormal trading
which could be indicative of an uninformed market and which may raise continuous disclosure concerns. The
increase in price of GMC’s shares on 9 December 2016 was not such as to give ASX a reason to suspect that
the trading on that day was abnormal.
ASX does acknowledge that GMC’s share price did increase steadily from a low of 0.016 on 9 November 2016
to its high of $0.043 on 9 December but that is not necessarily indicative of an uninformed market.
If you are concerned that insider trading or market manipulation has occurred in GMC, then we encourage
you to pursue that matter further with the Australian Securities Investments Commission (“ASIC”) as that
falls with ASIC’s jurisdiction. More information about the types of matters that fall within ASX’s jurisdiction
and those that fall within ASIC’s jurisdiction can be found it on our website at:
http://www.asx.com.au/documents/about/corporations-act-vs-listing-rules-matters.pdf
You can lodge your complaint using ASIC’s online complaint service. This will ensure that the complaint is
logged in your name and that ASIC can communicate directly with you about the complaint.
You can access the ASIC complaint service at:
http://www.asic.gov.au/about-asic/contact-us/how-to-complain/
We hope this letter has helped to clarify the situation.
Yours sincerely
[sent electronically without signature]





I laugh that the ASX didn't think the announcements had a material effect on the share price..

Why suspend GMC the first time to seek assurances re the Co of your not vetting them..