Alara Resources : Response to ASX Appendix 3X Query

Alara Resources Limited	Telephone |	[phone]
A.B.N. 27 122 892 719	Facsimile	|	[phone]
Suite 1.02, 110 Erindale Road,	Web	|	www.alararesources.com
Balcatta WA 6021, Australia	Email	|	[e-mail]

PO Box 963, Balcatta WA 6914

8 December 2020

Ms S Patchell

Adviser, Listings Compliance (Perth)

Level 40, Central Park

152-158 St George's Terrace

Perth WA 6000

By Email: [e-mail]

Dear Madam,

Alara Resources Limited ("AUQ" or"the Company")

We refer to your letter dated 4 December 2020, and provide the following responses as requested:

1. Please explain why the Appending 3X was lodged late.

The late lodgement of the Appendix 3X for Mr Sanjeev Kumar was an administrative oversight.

2. What arrangements does AUQ have in place under Listing Rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?

The Company acknowledges its disclosure obligations under Listing Rule 3.19A and has in place policies to enable it to comply with its continuous and other disclosure obligations (see, for example, the Continuous Disclosure Policy, referred to in section 5.1 of the Company's Corporate Governance Statement). In particular, it is a provision of the agreements which the Company has with each of its Directors, including Mr Kumar, that they give the Company the information within their knowledge which it requires to enable it to comply with LR 3.19A and related rules. The Director gave the Company the required information at the time of his appointment, however lodgement of an Appendix 3X reflecting that information was overlooked by inadvertence.

3. If the current arrangements are inadequate or not being enforced, what additional steps does AUQ intend to take to ensure compliance with Listing Rule 3.19B?

It is considered that the Company's current arrangements are adequate and are enforced, with the exception of this single, inadvertent breach.

For further information, please contact the writer.

Yours faithfully,

Dinesh Aggarwal

Company Secretary

ASX Code | AUQ

4 December 2020

Reference: 28601

Mr Dinesh Aggarwal

Company Secretary

Alara Resources Limited

By email: [e-mail]

Dear Mr Aggarwal

Alara Resources Limited ('AUQ'): Appendix 3X - Initial Director's Interest Notice Query

ASX refers to the following:

1. AUQ's announcement lodged on the ASX Market Announcements Platform ('MAP') on 26 October 2020 confirming the appointment of Mr Sanjeev Kumar as a director of AUQ effective on 23 October 2020;
2. AUQ's Appendix 3X lodged on the ASX Market Announcements Platform ('MAP') on 2 December 2020 for Mr Kumar (the 'Notice');
3. Listing Rule 3.19A which requires an entity to tell ASX the following:

3.19A.1	'The notifiable interests of a director of the entity (or in the case of a trust, a director
	of the responsible entity of the trust) at the following times.
	∙	On the date that the entity is admitted to the official list.
	∙	On the date that a director is appointed.
	The entity must complete Appendix 3X and give it to ASX no more than 5 business
	days after the entity's admission or a director's appointment.
3.19A.2	A change to a notifiable interest of a director of the entity (or in the case of a trust, a
	director of the responsible entity of the trust) including whether the change occurred
	during a closed period where prior written clearance was required and, if so, whether
	prior written clearance was provided. The entity must complete Appendix 3Y and
	give it to ASX no more than 5 business days after the change occurs.
3.19A.3	The notifiable interests of a director of the entity (or in the case of a trust, a director
	of the responsible entity of the trust) at the date that the director ceases to be a

director. The entity must complete Appendix 3Z and give it to ASX no more than 5 business days after the director ceases to be a director.'

4. Listing rule 3.19B which states that:

'An entity must make such arrangements as are necessary with a director of the entity (or in the case of a trust, a director of the responsible entity of the trust) to ensure that the director discloses to the entity all the information required by the entity to give ASX completed Appendices 3X, 3Y and 3Z within the time period allowed by listing rule 3.19.A. The entity must enforce the arrangements with the director.'

As the Notice indicated that Mr Kumar was appointed on 23 October 2020, it appears that the Notice should have been lodged with ASX by 30 October 2020. As the Notice was lodged on 2 December 2020, it appears that AUQ may have breached listing rules 3.19A and/or 3.19B. It also appears that Mr Kumar may have breached section 205G of the Corporations Act 2001(Cth).

ASX Limited [[Listings]]

ASX Customer Service Centre 131 279 | asx.com.au

Request for Information

Under Listing Rule 18.7, we ask that you answer each of the following questions having regard to Listing Rules 3.19A and 3.19B and Guidance Note 22: Director Disclosure of Interests and Transactions in Securities - Obligations of Listed Entities.

1. Please explain why the Appendix 3X was lodged late.
2. What arrangements does AUQ have in place under Listing Rule 3.19B with its directors to ensure that it is able to meet its disclosure obligations under Listing Rule 3.19A?
3. If the current arrangements are inadequate or not being enforced, what additional steps does AUQ intend to take to ensure compliance with Listing Rule 3.19B?

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 10.00am AWST on Wednesday, 9 December 2020. 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, AUQ'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 and may require AUQ to request a trading halt immediately.

Your response should be sent to me by e-mail at [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.

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 AUQ'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 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 AUQ's securities under Listing Rule 17.3.

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ASX Customer Service Centre 131 279 | asx.com.au

Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to AUQ'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 AUQ'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.

Release of correspondence between ASX and entity

We reserve the right to release a copy of this letter, your reply and any other related correspondence between us to the market under Listing Rule 18.7A.

Questions

If you have any questions in relation to the above, please do not hesitate to contact me.

Yours sincerely

Stephanie Patchell

Adviser, Listings Compliance (Perth)

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ASX Customer Service Centre 131 279 | asx.com.au