COMPLYING WITH THE ASX LISTING RULES AND DISCLOSURE REQUIREMENTS

Purpose

To ensure that the Imdex Limited Group, as an ASX Listed Public Company, complies with the disclosure requirements of the ASX Listing Rules.  To ensure that senior management are accountable for ensuring compliance with these requirements.

Requirements

ASX Listing Rules, Chapter 3, requires the immediate notification of price sensitive information and other defined information. The ASX Listing Rules (LR) require that once Imdex becomes aware of 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, it must immediately tell ASX that information.  There are a number of exceptions to this rule set out in LR3.1. The LR’s also require periodic disclosure of certain information in Imdex’s Annual and Half-Yearly Financial Reports.

Procedure

1. Information is determined by the Managing Director, Board, Company Secretary or other employee of the Company as being of a type or nature that warrants disclosure
2. If not known by the Managing Director, this information should be reported to the Managing Director
3. The Managing Director will determine the nature and extent of the information and consult with the Chairman to determine the form and content of any ASX Release (Release)
4. The Managing Director and Chairman will jointly agree on the text of the proposed Release.  The Company Secretary may also be required to draft the Release for review
5. The Company Secretary will then distribute the Release to the Board for their review and comment.  Following consultation with the Chairman, the Company Secretary will allow such time as is reasonable in the circumstances for the each Director to comment on the Release
6. The Company Secretary will inform the Chairman and Managing Director of each Directors’ comments and together with the Chairman and Managing Director make any necessary changes to the Release
7. Following authorisation from the Chairman or Managing Director, the Company Secretary will then release the ASX Release to the market, and ensure that the Company’s Website is updated

Additional Procedures

Depending on the nature of the Release the Managing Director in consultation with the Chairman shall determine whether, and to what extent:

1. There are additional media releases, comments or other contacts made
2. Whether shareholders or analysts will be briefed about the Release

Responsibility

Primary Responsibility

Managing Director.

Secondary Responsibility