Announcement PDF WHERE BIOTECHNOLOGY & N A N O T E C H N O L OG Y MEET 31 December 2019 Cheng Teng Senior Adviser, Listings Compliance (Melbourne) Level 4, 525 Collins St Melbourne VIC 3000 By email only: Dear Cheng, Imagion Biosystems Limited (the Company) We refer to your letter to the Company dated 31 December 2019 entitled Imagion Biosystems Limited (‘IBX’): Price Query. We respond to each of your queries as follows (adopting your numbering): 1. Is IBX 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? The Company is not aware of any information that could explain the recent trading in its securities. 2. If the answer to question 1 is “yes”: a. Is IBX relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? Not Applicable b. Can an announcement be made immediately? Not Applicable c. If an announcement cannot be made immediately, why not and when is it expected that an announcement will be made? Not Applicable 3. If the answer to question 1 is “no”, is there any other explanation that IBX may have for the recent trading in its securities? The Company is not aware of any matter that would have affected the recent trading in its securities. 4. Please confirm that IBX is complying with the Listing Rules and, in particular, Listing Rule 3.1. The Company confirms it is complying with the Listing Rules and, in particular, Listing Rule 3.1. Imagion Biosystems Limited ACN 616 305 027 Level 8, 555 Bourke Street, Melbourne VIC 3000 www.imagionbiosystem.com WHERE BIOTECHNOLOGY & N A N O T E C H N O L OG Y MEET 5. Please confirm that IBX’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 IBX with delegated authority from the board to respond to ASX on disclosure matters. This response has been authorised and approved by the Company’s Disclosure Committee in accordance with the Disclosure and Communication Policy. Yours sincerely Mr Robert Proulx Executive Chairman and President Approved by the Disclosure Committee of Imagion Biosystems Limited --ENDS-- Imagion Biosystems Limited ACN 616 305 027 Level 8, 555 Bourke Street, Melbourne VIC 3000 www.imagionbiosystem.com 31 December 2019 Reference: ODIN12134 Mr Hasaka Martin Company Secretary Imagion Biosystems Limited By email only Dear Mr Martin Imagion Biosystems Limited (‘IBX’): Price Query We note the change in the price of IBX’s securities from a low of $0.024 at market open to a high of $0.029 today, at the time of writing. We also note the significant increase in the volume of IBX’s securities traded today. Request for Information In light of this, ASX asks IBX to respond separately to each of the following questions and requests for information: 1. Is IBX 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 IBX is aware of any information that its earnings for the 12 month period ending on 31 December 2019: (a) are likely to differ materially (downwards or upwards) from any earnings guidance it has given for the period; or (b) if IBX 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 IBX is not covered by analysts, its earnings for the prior corresponding period)? 2. If the answer to question 1 is “yes”. (a) Is IBX relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? Please note that the recent trading in IBX’s securities would suggest to ASX that such information may have ceased to be confidential and therefore IBX 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 IBX may have for the recent trading in its securities? 4. Please confirm that IBX is complying with the Listing Rules and, in particular, Listing Rule 3.1. ASX Limited [[Listings]] ASX Customer Service Centre 131 279 | asx.com.au 5. Please confirm that IBX’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 IBX 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 2:00 PM AEDT today Tuesday, 31 December 2019. If we do not have your response by then, ASX will likely suspend trading in IBX’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, IBX’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 ListingsComplianceMelbourne@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 IBX’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 IBX’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 IBX’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 2/3 ASX Customer Service Centre 131 279 | asx.com.au If you are unable to respond to this letter by the time specified above ASX will likely suspend trading in IBX’s securities under Listing Rule 17.3. Enquiries If you have any queries or concerns about any of the above, please contact me immediately. Yours sincerely Cheng Tang Senior Adviser, Listings Compliance (Melbourne) 3/3 ASX Customer Service Centre 131 279 | asx.com.au