4 September 2015
Jeremy Newman
Adviser, Listings Compliance (Perth) ASX Compliance Pty Ltd
Level 40, Centrai Park
152-158 St Georges Terrace
Perth WA 6000
Panorama Synergy LtdLeve! 7
99 Macquarie Street
Sydney NSW 2000
ACN 060 369 048
By Email: jeremy.newman@asx.com.au; tradinghaltsperth@asx.com.auDear Jeremy,
Panorama Synergy Limited (the 'Company') Response to ASX Price and Volume Query (ASX Query)We refer to the ASX Query dated 4 September 2015 and respond to each of the questions as follows:
1. No. The Company is not aware of any information that has not been announced to the market.
2. (a) Not applicable. (b) Not applicable. (c) Not applicable.
3. On 3 September 2015 The Australian1 ran a feature story on the MEMS industry, sensors and specifically Panorama Synergy Limited and our Managing Director, Mr Terry Walsh. The artide can be found on our website www.panoramasynergy.com
The artide noted that sensor technology is already an $86 billion global market, with the MEMS industry tipped to be worth $14bn a year worldwide.
The Company continues to establish strategie alliances and commerciai agreements in and related to the MEMS industry and continues the "stepping stones' in our development and evolution to commercialisation.
4. We confirm that the Company is in compliance with the Listing Rules and, in particular
Listing Rule 3.1.
4 September 2015
Mr Anthony Karam Company Secretary Panorama Synergy Limited
By email
Dear Mr Karam
We have noted a change in the price of the Company's securities from a closing price of $0.10 on Wednesday, 2 September 2015, to an intra-day high of $0.165 today, 4 September 2015. We have also noted an increase in the volume of trading in Company's securities over this period.
In light of the price and volume increase, ASX asks you to respond separately to each of the following questions:
1. Is the Entity 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 the Entity relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? | |
Please note that the recent trading in the Entity's securities would suggest to ASX that such information may have ceased to be confidential and therefore the Entity 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 announcemant will be made? | |
3. | If t rec | he answer to question 1 is "no", is there any other explanation that the Entity may have for the ent trading in its securities? |
ASX Compliance
Pty Limited
ABN 26 087 780 489
Level 40, Central Park
152-158 St George's Terrace
Perth WA 6000
www.asx.com.au
Customer service 13 12 79
T 61 8 9224 0029
E Jeremy.newman@asx.com.au
4. Please confirm that the Entity is in compliance with the Listing Rules and, in particular, Listing
Rule 3.1.
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 11.00am AWST today, Friday, 4 September 2015. If we do not have your response by then, ASX will have no choice but to consider suspending trading in the Entity'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 Entity'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 jeremy.newman@asx.com.au and tradinghaltsperth@asx.com.au. It should notbe 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 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 Entity 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 Entity's obligations under Listing Rules 3.1 and
3.1A and also to Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 - 3.1B.
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 Entity's securities under Listing Rule 17.1.
If you wish a trading halt, you must tell us:
the reasons for the trading halt;
2/3
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.
If you have any queries or concerns about any of the above, please contact me immediately. Yours sincerely
[sent electronically without signature]
Jeremy Newman
Senior Adviser, ASX Listings Compliance3/3
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