Response to ASX Price Query
Released
Released
Announcement PDF
1 April 2019
Lisa Banh
Senior Listings Adviser, Listings Compliance
ASX Compliance Pty Ltd
20 Bridge St
SYDNEY NSW 2000
Dear Lisa
RESPONSE TO PRICE QUERY
I refer to your letter to Invion Limited (“Company”) dated 1 April 2019, and respond to your questions as
follows:
1.
The Company is not aware of any information concerning it that has not been announced to
the market which, if known by some in the market, could be an explanation for recent trading
in the securities of the Company.
2.
In light of 1. above, not applicable.
3.
On 29 February 2019, the Company lodged a Corporate Update and Investor Presentation
outlining the clinical strategy for its development of the PhotosoftTM technology and the
forward focus of the Company. The presentation was to accompany meetings being
undertaken by MD & CEO, Dr Greg Collier during March 2019.
On 29 March 2019, NDF Research (“NDF”) published research initiating coverage on the
Company. This commissioned research was published to NDF’s subscriber base, to Invion’s
website and to Invion’s subscriber base.
On 1 April 2019, an email was distributed to subscribers of Hot Copper which linked to a
sponsored ‘Corporate Spotlight’. The sponsor of the Corporate Spotlight, Vantage Point
Partners, provided a description of Invion, a summary of key points of the NDF report and a link
to the research report.
Aside from this information, the Company does not have any other explanation for the recent
trading of its securities.
4.
The Company is in compliance with the Listing Rules and, in particular, Listing Rule 3.1.
5.
The Company confirms that its responses provided above have been authorised and
approved in accordance with its published continuous disclosure policy and by an officer of
the Company with delegated authority from the Board to respond to ASX on disclosure
matters.
Yours sincerely
Melanie Farris
Company Secretary
Invion Limited ABN 76 094 730 417
722 High Street, East Kew, VIC 3102 Australia
P: +61 3 9081 6005 W: www.inviongroup.com
1 April 2019
Ms Melanie Farris
Company Secretary
Invion Limited
Unit 2, 120 Bluestone Circuit
Seventeen Mile Rocks QLD 4073
By email:
Dear Ms Farris
Invion Limited (‘IVX’): Price Query
We note the change in the price of IVX’s securities from a low of $1.3 cents to a high of $1.8 cents today.
We also note the significant increase in the volume of IVX’s securities traded from 29 March 2019 to 1 April
2019.
Request for Information
In light of this, ASX asks IVX to respond separately to each of the following questions and requests for
information:
1. Is IVX 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 IVX relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? Please
note that the recent trading in IVX’s securities would suggest to ASX that such information may
have ceased to be confidential and therefore IVX 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 IVX may have for the recent trading in
its securities?
4. Please confirm that IVX is complying with the Listing Rules and, in particular, Listing Rule 3.1.
5. Please confirm that IVX’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 IVX 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 Listing Rule 18.7. Your response is required as soon as reasonably possible and, in
any event, by no later than 3:00 PM AEST today Monday, 1 April 2019. If we do not have your response by
then, ASX will likely suspend trading in IVX’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, IVX’s obligation is to disclose the
ASX Limited [[Listings]]
ASX Customer Service Centre 131 279 | asx.com.au
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 ListingsComplianceSydney@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.
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 IVX’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 IVX’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, 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 IVX’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.
Suspension
If you are unable to respond to this letter by the time specified above ASX will likely suspend trading in IVX’s
securities under Listing Rule 17.3.
Enquiries
If you have any queries or concerns about any of the above, please contact me immediately.
Regards
Lisa Banh
Senior Adviser, Listings Compliance (Sydney)
2/2
ASX Customer Service Centre 131 279 | asx.com.au
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