Announcement PDF 13 July 2015 Isabella Wong ASX Compliance Pty Ltd 20 Bridge St SYDNEY NSW 2000 Dear Isabella RESPONSE TO PRICE QUERY I refer to your letter to Invion Limited (“Company”) dated 13 July 2015, and respond to your questions, using the numbering in your letter, as follows: 1. The Company is not aware of any specific information concerning it that has not been announced which, if known, could be an explanation for recent trading in the securities of the Company. 2. In light of 1. above, not applicable. 3. The Company notes the following potential explanations: i. a recent announcement released by the Company on 3 July 2015 regarding an update on key milestones for the Company’s drug development programs; and ii. newspaper publications on 5 July 2015 which included ‘share price tips’ in respect of the Company. Aside from information that is in the public domain or as noted above, the Company does not have any other explanation for the price change of the Company's securities. 4. The Company is in compliance with the Listing Rules and, in particular, Listing Rule 3.1. Yours sincerely Melanie Farris Company Secretary Invion Limited ABN 76 094 730 417 GPO Box 1557, Brisbane, QLD, 4001. P +61 7 3295 0500 F +61 7 3295 0599 www.inviongroup.com 13 July 2015 Ms Melanie Farris Company Secretary Invion Limited Level 11, 66 Eagle Street Brisbane QLD 4000 By Email Dear Ms Farris, Invion Limited (the “Company”): ASX price query We have noted a change in the price of the Company’s securities from a low of 1.9 cents on Monday, 6 July 2015 to an intra-day high of 3.1 cents at the time of writing today, Monday, 13 July 2015. We also note an increase in the trading volumes of the Company’s securities. In light of the price and volume increase ASX asks you to respond separately to each of the following questions: 1. Is the Company 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? In responding to this question, please consider in particular whether the Company is aware of any information that its earnings for the 12 month period ended on 30 June 2015: 2. a) are likely to differ materially (downwards or upwards) from any earnings guidance it has given for the period; or b) if the Company has not given any earnings guidance for the period, are otherwise likely to come as a surprise to the market (by reference to analyst forecasts for the period or, if the Company is not covered by analysts, its earnings for the prior corresponding period)? If the answer to question 1 is “yes”: a) Is the Company relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? Please note that the recent trading in the Company’s securities would suggest to ASX that such information may have ceased to be confidential and therefore the Company 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). ASX Compliance Pty Limited ABN 26 087 780 489 20 Bridge Street Sydney NSW 2000 www.asx.com.au Customer service 13 12 79 c) If an announcement cannot be made immediately, why not and when is it expected that an announcemant will be made? 3. If the answer to question 1 is “no”, is there any other explanation that the Company may have for the recent trading in its securities? 4. Please confirm that the Company is in compliance with the Listing Rules and, in particular, Listing Rule 3.1. 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 2:15 PM AEST on 13 July 2015. If we do not have your response by then, ASX will have no choice but to consider suspending trading in the Company’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, the Company’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. 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 Rule 3.1 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. The obligation of the Company to disclose information under Listing Rules 3.1 and 3.1A is not confined to, nor is it necessarily satisfied by, answering the questions set out in this letter. In responding to this letter, you should have regard to the Company’s obligations under Listing Rules 3.1 and 3.1A and also to Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 – 3.1B. 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 the Company’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. 2/3 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. If you have any queries or concerns about any of the above, please contact me immediately. Yours sincerely, [Sent electronically without signature] Isabella Wong Adviser, Listings Compliance (Sydney) 3/3