Tanami Gold NL : Response to ASX Aware Letter

TANAMI GOLD NL

17 February 2017

Ms Hayley Pratt Adviser

Listings Compliance (Perth) ASX Limited

Perth WA 6000

e: [e-mail]

Dear Hayley

In response to your letter dated 16 February 2017, and following conversations that I have had with you on this matter previously, our response to your questions are as follows:

1. Tanami Gold NL ("Tanami or the Company") does not consider that the exploration results would have a material effect on the price or volume of its securities.

2. The drilling results are preliminary investigations of an arsenic anomaly defined on the tenements. It was the continuation of an aborted drilling programme commenced during the September quarter (results published). The results are not resource defining, purely interpretive.

3. Not Applicable

4. Not Applicable

5. The Company is in compliance with the Listing Rules, in particular Listing Rule 3.1 which relates to continuous disclosure.

6. We confirm that Brett Montgomery has the authority from the Board to respond to the ASX on disclosure matters.

Brett Montgomery Director

Suite B1, Tempo Building, 431 Roberts Road, Subiaco WA 6008  P.O. Box 1892, West Perth, Western Australia, 6872

Tel: [phone]  Fax: [phone]  Email: [e-mail]  Website: www.tanami.com.au.  ABN: 51 000 617 176

16 February 2017

Ms Pauline Collinson Company Secretary Tanami Gold NL

PO Box 1892

WEST PERTH 6872

By email: [e-mail] Dear Ms Collinson

TANAMI GOLD NL ("TAM"): aware query

ASX Limited ("ASX") refers to the following:

1. TAM's announcement entitled "Quarterly Activities Report and Appendix 5B" lodged on the ASX Market Announcements Platform and released at 5:17 pm on 30 January 2017 (the "Quarterly Report"), summarizing the Company's quarterly activities for the quarter ended 31 December 2016. On page 2 in the section titled "Western Tanami Project (100% Tanami)", TAM states that thirty-three reverse circulation holes totalling 3,252m were completed at Rabid South and the Nugget Patch during November 2016 and in the section titled "Table 1 Significant gold intercepts" lists the significant intercepts. On pages 6 - 10 in the sections titled "Table 2 Rabid South and Nugget Patch drill hole details" and "JORC Code, 2012 edition - July 2016 Aircore Drilling", TAM provides full details pertaining to the drilling results ("Exploration Results").

2. The Exploration Results had not previously been disclosed to the market prior to the Quarterly Report.

3. Listing Rule 3.1, which 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.

4. The definition of "aware" in Chapter 19 of the Listing Rules, which states that:

   "an entity becomes aware of information if, and as soon as, an officer of the entity (or, in the case of a trust, an officer of the responsible entity) has, or ought reasonably to have, come into possession of the information in the course of the performance of their duties as an officer of that entity"

   and section 4.4 in Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 - 3.1B "When does an entity become aware of information".

5. Listing Rule 3.1A, which sets out exceptions from the requirement to make immediate disclosure, provided that each of the following are satisfied.

   "3.1A Listing rule 3.1 does not apply to particular information while each of the following is satisfied in relation to the information:

   ASX Compliance Pty Limited ABN 26 087 780 489

   20 Bridge Street

   Sydney NSW 2000

   www.asx.com.au Customer service 13 12 79

6. A.1 One or more of the following applies:

   • It would be a breach of a law to disclose the information;

   • The information concerns an incomplete proposal or negotiation;

   • The information comprises matters of supposition or is insufficiently definite to warrant disclosure;

   • The information is generated for the internal management purposes of the entity; or

   • The information is a trade secret; and

7. 3.1A.2 The information is confidential and ASX has not formed the view that the information has ceased to be confidential; and

   3.1A.3 A reasonable person would not expect the information to be disclosed."

8. ASX's policy position on the concept of "confidentiality", which is detailed in section 5.8 of Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 - 3.1B. In particular, the Guidance Note states that:

   "Whether information has the quality of being confidential is a question of fact, not one of the intention or desire of the listed entity. Accordingly, even though an entity may consider information to be confidential and its disclosure to be a breach of confidence, if it is in fact disclosed by those who know it, then it ceases to be confidential information for the purposes of this rule."

   Having regard to the above, ASX asks TAM to respond separately to each of the following questions and requests for information:

9. Does TAM consider the Exploration Results or any part thereof, to be information that a reasonable person would expect to have a material effect on the price or value of its securities?

10. If the answer to question 1 is "no", please advise the basis for that view.

11. If the answer to question 1 is "yes", when did TAM first become aware of the Exploration Results or any part thereof?

12. If the answer to question 1 is "yes" and TAM first became aware of the Exploration Results, or any part thereof, before 30 January 2017, did TAM make any announcement prior to the relevant date which disclosed the Exploration Results? 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 TAM was obliged to release the Exploration Results, or any part thereof, under Listing Rules 3.1 and 3.1A and what steps TAM took to ensure that the Exploration Results were released promptly and without delay.

13. Please confirm that TAM is in compliance with the Listing Rules and, in particular, Listing Rule 3.1.

14. Please confirm that TAM'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 TAM with delegated authority from the board to respond to ASX on disclosure matters.

15. 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 12:00 p.m. WST on Monday, 20 February 2017. If we do not have your response by then, ASX will have no choice but to consider suspending trading in TAM'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, TAM'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 [e-mail] and to [e-mail]. 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

    In responding to this letter, you should have regard to TAM'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 TAM'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, you should discuss with us whether it is appropriate to request a trading halt in TAM'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 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.