Response to Query
Released
Released
Announcement PDF
29 November 2023
Reference: 85654
Ms Ash Abdul Aziz
Adviser, Listings Compliance
ASX
By email: ListingsComplianceMelbourne@asx.com.au
Dear Ash
Titomic Limited (‘TTT’): Price – Query
Thank you for your letter dated 29 November.
In response to your Request for Information, I would comment on your numbered paragraphs as
follows:
1.
2.
3.
4.
5.
No, so far as we are aware;
N/A;
No, so far as we are aware;
Confirmed, so far as we are aware;
Confirmed.
Kind regards
Chris Healy
Company Secretary
Titomic Limited Ground floor, 365 Ferntree Gully Road
Mount Waverley, Victoria 3149, Australia
info@titomic.com | titomic.com
ABN 77 602 793 644
1
29 November 2023
Reference: 85654
Mr Chris Healy
Company Secretary
Titomic Limited
Ground Floor, 365 Ferntree Gully Road
Mount Waverly, VIC 3149, Australia
By email: chris.healy@titomic.com
Dear Mr Healy
Titomic Limited (‘TTT’): Price - Query
ASX refers to the following:
A. The change in the price of TTT’s securities from a low of $1.6 to a high of $2.2 today.
B. The significant increase in the volume of TTT’s securities traded from 28 November 2023 to 29 November
2023.
Request for information
In light of this, ASX asks TTT to respond separately to each of the following questions and requests for
information:
1. Is TTT 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 TTT relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1?
Please note that the recent trading in TTT’s securities would suggest to ASX that such information
may have ceased to be confidential and therefore TTT 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
announcement will be made?
3. If the answer to question 1 is “no”, is there any other explanation that TTT may have for the recent trading
in its securities?
4. Please confirm that TTT is complying with the Listing Rules and, in particular, Listing Rule 3.1.
5. Please confirm that TTT’s responses to the questions above have been authorised and approved under its
published continuous disclosure policy or otherwise by its board or an officer of TTT with delegated
authority from the board to respond to ASX on disclosure matters.
When and where to send your response
ASX Limited [[Listings]]
#10663523v1
ASX Customer Service Centre 131 279 | asx.com.au
This request is made under Listing Rule 18.7. Your response is required as soon as reasonably possible and, in
any event, by no later than 9 AMAEDT Thursday, 30 November 2023. 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, TTT’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 and may require TTT to request a trading halt immediately.
Your response should be sent to me by e-mail at ListingsComplianceMelbourne@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.
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 TTT’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.
We 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.
Suspension
If you are unable to respond to this letter by the time specified above, ASX will likely suspend trading in TTT’s
securities under Listing Rule 17.3.
Listing Rules 3.1 and 3.1A
In responding to this letter, you should have regard to TTT’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 TTT’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.
Release of correspondence between ASX and entity
ASX reserves the right to release all or any part of this letter, your reply and any other related correspondence
between us to the market under Listing Rule 18.7A.
Questions
If you have any questions in relation to the above, please do not hesitate to contact me.
Kind regards
2/3
ASX Customer Service Centre 131 279 | asx.com.au
#10663523v1
Ash Abdul Aziz
Adviser, Listings Compliance
3/3
ASX Customer Service Centre 131 279 | asx.com.au
#10663523v1
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