Im sending this . Feel free to send to Dominic StephensDear Mr...

Im sending this . Feel free to send to Dominic Stephens


Dear Mr Stephens

I write to you on a matter of grave concern to myself as a shareholder of iSignthis Ltd, but also as a shareholder in a number of ASX listed entities.

Over the course of the last two months, my confidence in the ASX as the market operator has been shaken significantly.

Firstly, the suspension of ISX without any firm allegations having been raised by the ASX. "Market Volatility" is and never was the issue.

Secondly, suspension of ISX without allowing the Company to be heard in the first instance. ASX Guidelines are clear that suspension is a "last resort". Suspending without notice is not only a denial of natural justice, it is also a perversion of due process and lacks any procedural fairness. This undermines the integrity of the ASX as the market operator. Listed entities must be able to rely upon the listing rules such that they can plan and operate in regime that is consistent. The ASX's actions appear to have been capricious, and not based on a system that would instill confidence in market participants, be they shareholders, investors or companies.

Thirdly, the disclosure requested of ISX was well outside what appears to have been necessary. The ASX cold have asked its questions, assessed the answers, and then agreed appropriate disclosure that would be required by the Company. The process undertaken by the ASX was embarrassing for the ASX, and is almost certainly likely to have harmed ISX. It also appeared to have been pointless, as, whilst a lot if information was disclosed, not much of it is relevant to 2019.

Fourthly, we are led to believe that ISX directors and its major shareholders who received performance rights offerred to place their performance right shares into voluntary escrow, whilst the Q&A process of step 3 above was undertaken. This was such that small holders like myself could trade, and, had it been in conjunction with a discreet Q&A process, would have alleviated liquidity and anxiety concerns of smaller holders. There is no doubt that the Consideration shares for vending in the original iSignthis entity were due, so, even if shares are considered fungible (which they are), the iSIgnthis vendor was and is entitled to those anyway.

Fifthly, the presumption of guilt and prejudice is appalling. Westpac, ANZ, CBA are all facing (ro have admitted to), serious criminal charges. Yet, these are all trading on the ASX. Once again, capricious action outside of the rule of law undermines the ASX as market operator.

Sixthly, the revelations today that one of the ASX directors holds an interest in a competitor of ISX is cause for alarm, especially given the amount of disclosure that ISX has made to the ISE regarding its operations appear to be extensive.

Wodi Wodi Pty Ltd is a substantial shareholder of ASX: ID8, a company that is competitive to ISX, of which Mr Roche is a a shareholder of 5.6% (substantial)

Can the ASX confirm that;

Mr Roche has not been involved in any discussions or privy to any information provided by ISX to ASX?
Mr Roche has declared his conflict of interest?

Does the ASX have an active conflict of interest register?

Mr Roche has not voted on any matters related to ISX?

Mr Roche has not directed any ASX staff with regards to ISX?

Finally, the ASX has still not provided a cogent reason or allegation towards why ISX is suspended. It is astounding that in a Western Democracy, built upon the rule of law, that an entity can be fund 'guilty' of a transgression that has yet to be articulated, suspended under a rule (17.3) without the supporting reason, and yet still be expected to defend itself from nameless accusers and an formless accusation.

I call on you, on behalf of all shareholders, to either state the allegation so it may be addressed, or, immediately lift the suspension and allow the securities to be traded.

Regards

A whole lot of ISX shareholders