St George's Terrace PERTH WA 6000
Dear Ms Pratt
RE: Response to ASX Price and Volume Query
We refer to the ASX price and volume query letter received from you on 10 January 2017. Set out below are the Company's responses to your questions (using the same numbered points contained in your letter):
The Company is not aware of any information that has not been announced to the market which, if known by some in the market, could explain recent trading in its securities.
In December 2016 the Company finalised a 12.5% cornerstone investment in the Company by Le Shan Shenghe Rare Earth Company Limited, a subsidiary of Shenghe Resources Holding Ltd (Shenghe). Shenghe's proficiency across all aspects of the rare earth industrial chain, combined with an international growth strategy, potentially make it an ideal industrial/strategic partner for the Company's Kvanefjeld Project (rare earths, uranium, zinc). As previously announced, both parties will commence technical cooperation that aims to further enhance the project. This will be conducted in parallel to project permitting that is currently progressing in Greenland.
In the lead up to finalising the Le Shan placement, the Company was the subject of increased coverage from brokers. This included a comprehensive research report by RM Research. In addition the Company noted increased buying of the Company's shares by Global X Uranium Exchange Traded Fund.
The Company confirms that is in compliance with Listing Rules, and in particular, Listing Rule 3.1
The Company's responses to the questions above have been authorised and approved in accordance with the Company's published continuous disclosure policy or otherwise by its board or an office of the Company with delegated authority from the board to respond to ASX on disclosure matters.
10 January 2017
Mr Miles Guy Company Secretary
Greenland Minerals and Energy Limited Ground Floor, Unit 6
100 Railway Road
SUBIACO WA 6008
By email: email@example.com Dear Mr Guy
Greenland Minerals and Energy Limited ("GGG"): price query
We note the change in the price of GGG's securities from a low of $0.076 to an intraday high of $0.089 today, Tuesday 10 January 2017.
We also note an increase in the trading volume of GGG's securities traded today, Tuesday 10 January 2017.
In light of this, ASX asks GGG to respond separately to each of the following questions and requests for information:
Is GGG 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?
If the answer to question 1 is "yes":
Is GGG relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1?
Please note that the recent trading in GGG's securities would suggest to ASX that such information may have ceased to be confidential and therefore GGG 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.
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).
If an announcement cannot be made immediately, why not and when is it expected that an announcemant will be made?
If the answer to question 1 is "no", is there any other explanation that GGG may have for the recent trading in its securities?
Please confirm that GGG 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
Please confirm that GGG'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 GGG 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 2.00 pm AWST (5:00pm AEDT) today Tuesday 10 January 2017. If we do not have your response by then, ASX will have no choice but to consider suspending trading in GGG'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, GGG'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 atHayley.Pratt@asx.com.auand firstname.lastname@example.org. 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 GGG'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 GGG'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.
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 GGG'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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