Response to ASX Price Query
Released
Released
Announcement PDF
18 September 2017
Dale Allen
Senior Advisor, Listimgs Compliance (Perth)
ASX Compliance Pty Limited
Level 40, Central Park
152 - 158 St Georges Terrace,
PERTH WA 6000
By email:
dale.allen@asx.com.au
tradinghaltsperth@asx.com.au
Dear Dale
Recce Limited (“the Company”) – ASX price and volume query
We refer to your query letter dated 18 September 2017 in relation to the change in the Company’s
share price and increase in the volume of trading in the Company’s securities traded on
18 September, in comparison to the closing price and trading activity on 15 September 2017. We
respond to each of the questions set out in the letter as follows:
1.
No
2.
a)
Not applicable
b)
Not applicable
c)
Not applicable
3.
The Company believes that the increase in both price and volume is the result of Channel 7
airing a program during their news segment on Friday evening the 15 September 2017.
4.
The Company is in compliance with the ASX Listing Rules, and in particular Listing Rule 3.1.
5.
The Company confirms that its responses above have been authorised and approved by an
officer of the Company with delegated authority from the Board.
Yours sincerely
Peter Williams
CFO & Company Secretary
18 September 2017
Mr Peter Williams
Suite 3, 3 Brodie-Hall Drive
Bentley WA 6102 Australia
By Email: peter.williams@recce.com.au
Dear Mr Williams
Recce Limited (“RCE”): price query
We note the change in the price of RCE’s securities from a low of $0.145 on 15 September 2017 to a high of
$0.26 at the time of writing today 18 September 2017.
We also note the media coverage RCE received on television news late last week and the significant increase
in the volume of RCE’s securities traded today, 18 September 2017.
In light of this, ASX asks RCE to respond separately to each of the following questions and requests for
information:
1.
Is RCE aware of any information concerning it that has not been announced to the market which, if
known by some in the market, could explain the recent trading in its securities?
2.
If the answer to question 1 is “yes”:
a)
Is RCE relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1?
Please note that the recent trading in RCE’s securities would suggest to ASX that such
information may have ceased to be confidential and therefore RCE may no longer be able to rely
on Listing Rule 3.1A. Accordingly, if the answer to this question is “yes”, you need to contact us
immediately to discuss the situation.
b)
Can an announcement be made immediately?
Please note, if the answer to this question is “no”, you need to contact us immediately to discuss
requesting a trading halt (see below).
c)
If an announcement cannot be made immediately, why not and when is it expected that an
announcemant will be made?
3.
If the answer to question 1 is “no”, is there any other explanation that RCE may have for the recent
trading in its securities?
4.
Please confirm that RCE is in compliance with the Listing Rules and, in particular, Listing Rule 3.1.
ASX Compliance Pty Limited
ABN 26 087 780 489
20 Bridge Street
Sydney NSW 2000
www.asx.com.au
Customer service 13 12 79
5.
Please confirm that RCE’s responses to the questions above have been authorised and approved in
accordance with its published continuous disclosure policy or otherwise by its board or an officer of
RCE with delegated authority from the board to respond to ASX on disclosure matters.
When and where to send your response
This request is made under, and in accordance with, Listing Rule 18.7. Your response is required as soon as
reasonably possible and, in any event, by not later than half an hour before the start of trading (ie before
12:00pm WST on Monday 18 September 2017. If we do not have your response by then, ASX will have no
choice but to consider suspending trading in RCE’s securities under Listing Rule 17.3.
You should note that if the information requested by this letter is information required to be given to ASX
under Listing Rule 3.1 and it does not fall within the exceptions mentioned in Listing Rule 3.1A, RCE’s
obligation is to disclose the information “immediately”. This may require the information to be disclosed
before the deadline set out in the previous paragraph.
ASX reserves the right to release a copy of this letter and your response on the ASX Market Announcements
Platform under Listing Rule 18.7A. Accordingly, your response should be in a form suitable for release to the
market.
Your response should be sent to me by e-mail at dale.allen@asx.com.au and tradinghaltsperth@asx.com.au.
It should not be sent directly to the ASX Market Announcements Office. This is to allow me to review your
response to confirm that it is in a form appropriate for release to the market, before it is published on the
ASX Market Announcements Platform.
Listing Rules 3.1 and 3.1A
Listing Rule 3.1 requires a listed 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.
Exceptions to this requirement are set out in Listing Rule 3.1A.
In responding to this letter, you should have regard to RCE’s obligations under Listing Rules 3.1 and 3.1A and
also to Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 – 3.1B.
It should be noted that RCE’s obligation to disclose information under Listing Rule 3.1 is not confined to, nor
is it necessarily satisfied by, answering the questions set out in this letter.
Trading halt
If you are unable to respond to this letter by the time specified above, or if the answer to question 1 is “yes”
and an announcement cannot be made immediately, you should discuss with us whether it is appropriate to
request a trading halt in RCE’s securities under Listing Rule 17.1.
If you wish a trading halt, you must tell us:
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; and
any other information necessary to inform the market about the trading halt, or that we ask for.
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We may require the request for a trading halt to be in writing. The trading halt cannot extend past the
commencement of normal trading on the second day after the day on which it is granted.
You can find further information about trading halts in Guidance Note 16 Trading Halts & Voluntary
Suspensions.
If you have any queries or concerns about any of the above, please contact me immediately.
Yours sincerely
[Sent electronically without signature]
Dale Allen
Senior Adviser, Listings Compliance (Perth)
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