TAWANA RESOURCES NL - Response letter to ASXRelease Date: 30/04/2018 09:07:00 Code(s): TAW PDF(s):
Response letter to ASX
Tawana Resources NL
(Incorporated in Australia)
(Registration number ACN 085 166 721)
Share code on the JSE Limited: TAW
JSE ISIN: AU0000TAWDA9
Share code on the Australian Securities Exchange Limited: TAW
ASX ISIN: AU000000TAW7
(“the Company” or “Tawana”)
Tawana Resources Response letter to ASX
We refer to your letter dated 26 April 2018. The Company provides the following responses:
1. Does the Entity consider the information in the Haulage Announcement to be information
(“Haulage Information”) that a reasonable person would expect to have a material effect
on the price or value of its securities?
No, the Company considers that the information in the Haulage Announcement is not
information that a reasonable person would expect to have a material effect on the price or
value of its securities.
2. If the answer to question 1 is “no”, please advise the basis for that view.
The movement of product from site to a port facility does not of itself constitute any material
new information. The Company has made several ASX announcements in the past three
months (and previously) referring to an anticipated first shipping date in April 2018, including
i. 15 February 2018 (Commissioning Commences at Bald Hill Lithium Plant)
ii. 14 March 2018 (Lithium Production Commences at Bald Hill)
iii. 16 March 2018 (Company Presentation)
iv. 29 March 2018 (Bald Hill Plant Achieves Key Milestones)
The Company has likewise provided regular updates to the market on construction,
commissioning and production activities at its Bald Hill Lithium and Tantalum mine.
The Company considers that the haulage and storage process is an implicit and integral part of
the shipping process. The Company further considers that it is reasonable to expect haulage to
follow plant commissioning and ore production and is an event which needs to occur prior to a
published anticipated shipping date. The Company therefore is of the opinion that the Haulage
Information is not new or unanticipated information that could be expected to have a material
effect on the price or value of its securities.
The Company further notes that, consistent with its response, its share price remained within the
range of $0.42 and $0.40 on the date of the Announcement and the following three trading days.
3. When did the Entity first become aware of the Haulage Information and the events
detailed below? In answering this question, please state the date and time that the Entity first
became aware of each of the following.
3.1. The Haulage Information. 19 April 2018.
3.2. Commencement of loading of the first road train carrying spodumene from Bald
Hill to the Port of Esperance. 20 April 2018.
3.3. Departure of the first loaded road train carrying spodumene from Bald Hill to
the Port of Esperance. 20 April 2018 12.50pm.
4. If the answer to question 1 is “yes” and the Entity first became aware of the Haulage
Information before the relevant date, did the Entity make any announcement prior to the
relevant date which disclosed the information? If so, please provide details. If not, please
explain why this information was not released to the market at an earlier time, commenting
specifically on when you believe the Entity was obliged to release the information under Listing
Rules 3.1 and 3.1A and what steps the Entity took to ensure that the information was released
promptly and without delay.
5. When did the Entity first become aware of each of the Twitter Post and the Hot Copper
Post? In answering this question, please state the date and time that the Entity first became
aware of each social media post.
The Company first became aware of each of the Twitter and the Hot Copper Posts at 3.05pm WST
on Thursday 26 April 2018 when alerted to the posts by the ASX.
6. Please detail the steps taken by the Entity to inform the market once it became aware
of each social media post.
No steps were taken as the Company has already made an announcement relating to the Haulage
Information by the time it became aware of the posts.
7. Does the Entity have any commercial, employment or other relationship with either the
person or persons behind @SmallCaps_asx or SU27? If the answer to this question is “yes”,
please detail the nature and terms of that relationship/s.
The Company is not aware of the identity of this person/s.
8. Does the Entity have any policies and procedures which govern the access to and
distribution or publication (including through social media) of the Entity’s information which
may be material to the price or value of the Entity’s securities by an employee, contractor, or
person otherwise permitted access to the Entity’s sites and/or information? If the answer to
this question is “yes”, please detail those policies and procedures and advise how they are
communicated to all such abovenamed persons.
The Company has a Code of Conduct which is available on the Company’s website which prohibits
the distribution or publication of the Company’s confidential information.
Tawana also has a Continuous Disclosure Policy which is available on the Company’s website
which provides that no Tawana Group employees or consultants are permitted to comment
publicly on matters confidential to the Tawana Group. Any information that is not public must be
treated by Tawana Group employees and consultants as confidential, until publicly released.
Compliance with the Company’s Code of Conduct and the Continuous Disclosure Policy is a
condition of employment for employees.
Contractors on site are subject to confidentiality provisions in their contracts which likewise
prohibit the distribution or publication of the Company’s confidential information. The Company
relies on Contractors to communicate these conditions to their own employees.
9. Does the Entity consider it appropriate that an employee, a contractor, or person
otherwise permitted access to Bald Hill and/or the Entity’s information, capture an image and
publish a social media post about or otherwise distribute information (including the Haulage
Information) which may be material to the price or value of the Entity’s securities before such
information is released to the market by the Entity through MAP?
The Company does not consider this to be appropriate and is currently investigating this matter.
10. Please confirm that the Entity is in compliance with the Listing Rules and, in particular,
Listing Rule 3.1.
The Company confirms it is in compliance with the Listing Rules and, in particular, Listing Rule 3.1.
11. Please confirm that the Entity’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 the Entity with delegated authority from the board to respond to ASX on
The Company confirms that the responses to the questions above have been authorised and
approved by the Managing Director in accordance with the Company’s published continuous
I would be pleased to provide any additional information that would be helpful to your office.
30 April 2018
PricewaterhouseCoopers Corporate Finance (Pty) Limited
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