20 December 2013
Ms Jill Hewitt
Senior Adviser Listings Compliance (Perth) ASX Compliance Pty Ltd
Level 8 Exchange Plaza
2 The Esplanade
PERTH WA 6000
Dear Ms Hewitt
Neptune Marine Services Ltd
ABN 76 105 665 843
Level 16, 140 St Georges Terrace
Perth, Western Australia, 6000
PO Box 7729, Cloisters Square, 6850
P +61 8 9424 1111
F +61 8 9424 1110
E info@neptunems.com
We enclose an Appendix 3X Initial Director's Interest Notice for each of Mr Boon Wee Kuah and
Mr Peter Wallace.
The Company acknowledges that these forms are significantly overdue. Messsrs Kuah and Wallace were appointed as directors of the Company on 16 March 2011 and 8 July 2011 respectively. Neptune acknowledges that Listing Rule 3.19A requires Appendix 3X to be lodged within 5 business days of the date that a director is appointed. Accordingly, the Appendix 3X for each of Messrs Kuah and Wallace should have been lodged by 23 March 2011 and 15 July 2011 respectively.
Neptune provides the following explanation in relation to the late lodgement:
1. The late lodgement was due to a combination of administrative oversight and a misunderstanding of the requirements of Listing Rule 3.19A. At the time of their appointment as directors of the Company, both Messrs Kuah and Wallace had a nil notifiable interest. The Company mistakenly believed that an Appendix 3X was not required in those circumstances. However the Company now realises that the obligation to lodge an Appendix 3X applies even if a director has no notifiable interest at the time of their appointment.
The Company has adopted this practice for subsequent director appointments (for example, the
Appendix 3X lodged 28 June 2013 for Mr Dominic Siu disclosed a nil holding).
2. The Company has written agreements in place with its directors that require the directors to notify the Company of their interests in the Company upon appointment and upon any change. These arrangements are in place to ensure that the Company can meet its disclosure obligations under Listing Rule 3.19A.
3. The Company considers that its current arrangements are adequate and no additional steps are required to ensure compliance with Listing Rule 3.19B. As explained above, the late lodgement was not caused by Messrs Kuah or Wallace.
Yours faithfully
General Counsel and Company Secretary
Appendix 3X
Initial Director's Interest Notice
Appendix 3X Initial Director's Interest NoticeRule 3.19A.1
Information or documents not available now must be given to ASX as soon as available. Information and
documents given to ASX become ASX's property and may be made public.
Introduced 30/9/2001.
Name of entity Neptune Marine Services Limited ABN 76 105 665 843We (the entity) give ASX the following information under listing rule 3.19A.1 and as agent for the director for the purposes of section 205G of the Corporations Act.
Part 1 - Director's relevant interests in securities of which the director is the registered holderIn the case of a trust, this includes interests in the trust made available by the responsible entity of the trust
Note: In the case of a company, interests which come within paragraph (i) of the definition of "notifiable interest of a director" should be disclosed in this part.
Number & class of securitiesNil
+ See chapter 19 for defined terms.
11/3/2002 Appendix 3X Page 1
Appendix 3X
Initial Director's Interest Notice
Part 2 - Director's relevant interests in securities of which the director is not the registered holderIn the case of a trust, this includes interests in the trust made available by the responsible entity of the trust
Name of holder & nature of interest Note: Provide details of the circumstances giving rise to the relevant interest. Nil Number & class of SecuritiesNil
Part 3 - Director's interests in contractsNote: In the case of a company, interests which come within paragraph (ii) of the definition of "notifiable interest of a director" should
be disclosed in this part.
Detail of contract | N/A |
Nature of interest | N/A |
Name of registered holder (if issued securities) | N/A |
No. and class of securities to which interest relates | N/A |
+ See chapter 19 for defined terms.
Appendix 3X Page 2 11/3/2002
Appendix 3X
Initial Director's Interest Notice
Appendix 3X Initial Director's Interest NoticeRule 3.19A.1
Information or documents not available now must be given to ASX as soon as available. Information and
documents given to ASX become ASX's property and may be made public.
Introduced 30/9/2001.
Name of entity Neptune Marine Services Limited ABN 76 105 665 843We (the entity) give ASX the following information under listing rule 3.19A.1 and as agent for the director for the purposes of section 205G of the Corporations Act.
Name of Director | Peter Wallace |
Date of appointment | 8 July 2011 |
In the case of a trust, this includes interests in the trust made available by the responsible entity of the trust
Note: In the case of a company, interests which come within paragraph (i) of the definition of "notifiable interest of a director" should be disclosed in this part.
Number & class of securitiesNil
+ See chapter 19 for defined terms.
11/3/2002 Appendix 3X Page 1
Appendix 3X
Initial Director's Interest Notice
Part 2 - Director's relevant interests in securities of which the director is not the registered holderIn the case of a trust, this includes interests in the trust made available by the responsible entity of the trust
Name of holder & nature of interest Note: Provide details of the circumstances giving rise to the relevant interest. Nil Number & class of SecuritiesNil
Part 3 - Director's interests in contractsNote: In the case of a company, interests which come within paragraph (ii) of the definition of "notifiable interest of a director" should
be disclosed in this part.
Detail of contract | N/A |
Nature of interest | N/A |
Name of registered holder (if issued securities) | N/A |
No. and class of securities to which interest relates | N/A |
+ See chapter 19 for defined terms.
Appendix 3X Page 2 11/3/2002
distributed by |