15 November 2011
Mr Darren Collins
Head of National Accounting Group/ Senior Adviser,
Listings
Australian Securities Exchange
Level 45, South Tower Rialto
525 Collins Street
Melbourne VIC 3000
Dear Mr Collins
Thankyou for your letter of 15 November 2011, received at 10.47am. In response to the questions you have asked, we advise as follows (using your question numbers):
1. Is the Company aware of any information concerning it that has not been announced which, if known, could be an explanation for recent trading in the securities of the Company?
The Company is not aware of any unannounced information concerning it that explains the recent trading in the Company's securities. The Company released an announcement this morning noting press speculation concerning Pacific Equity Partners' intention to make a proposal in relation to acquiring all of the outstanding shares in Spotless. The Company has not received a proposal and has not held any discussions with Pacific Equity Partners.
2. If the answer to question 1 is yes, can an announcement be made immediately? If not, why not and when is it expected that an announcement will be made?
Not applicable.
3. Is there any other explanation that the Company may have for the price change in the securities of the Company?
Apart from information already publicly released and the press speculation referred to at 1 above, the Company is not aware of any other explanation that may explain the price change in the Company's securities.
Spotless Group Limited ABN 77 004 376 514Level 6, 549 St Kilda Road, Melbourne VIC 3004 www.spotless.com T 03 92697277
4. Please confirm that the Company is in compliance with the listing rules and, in particular, listing rule 3.1.
I confirm that the Company is in compliance with the listing
rules and, in particular, listing rule
3.1.
Yours faithfully
Sharyn Page
Company Secretary
Level 6, 549 St Kilda Road, Melbourne VIC 3004 www.spotless.com T 03 92697277
ASX Compliance Pty Limited
ABN 26 087 780 489
Level 4
Rialto North Tower
525 Collins Street
Melbourne VIC 3000
15 November 2011
Ms Sharyn Page Company Secretary Spotless Group Limited
By email only
Dear Sharyn
Spotless Group Limited (the "Company")
RE: PRICE QUERY
GPO Box 1784
Melbourne VIC 3001
Telephone 61 3 9617 8711
Facsimile 61 3 9614 0303
www.asx.com.au
We have noted a change in the price of the Company's
securities from $2.20 at the close of trade on Friday, 11
November 2011, to a high of $2.45 at the time of writing
today.
In light of the price change, please respond to each of the
following questions.
1. Is the Company aware of any information concerning it that
has not been announced which, if known, could be an
explanation for recent trading in the securities of the
Company?
Please note that as recent trading in the Company's
securities could indicate that information has ceased to be
confidential, the Company is unable to rely on the exceptions
to listing rule 3.1 contained in listing rule 3.1A when
answering this question.
2. If the answer to question 1 is yes, can an announcement be
made immediately? If not, why not and when is it expected
that an announcement will be made?
Please note, if the answer to question 1 is yes and an
announcement cannot be made immediately, you need to contact
us to discuss this and you need to consider a trading halt
(see below).
3. Is there any other explanation that the Company may have
for the price change in the securities of the
Company?
4. Please confirm that the Company is in compliance with the
listing rules and, in particular, listing rule
3.1.
Your response should be sent to me by return e-mail or by
facsimile on facsimile number (03) 9614 0303. It should not
be sent to the Company Announcements Office.
Unless the information is required immediately under listing
rule 3.1, a response is requested as soon as possible and, in
any event, not later than 1:00 pm A.E.D.T today, 15 November
2011.
Under listing rule 18.7A, a copy of this query and your
response will be released to the market, so your response
should be in a suitable form and separately address each of
the questions asked. If you have any queries or concerns,
please contact me immediately.
Listing rule 3.1
Listing rule 3.1 requires an 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. The exceptions to this requirement are
set out in listing rule 3.1A.
In responding to this letter you should consult listing rule
3.1 and Guidance Note 8 - Continuous Disclosure:
listing rule 3.1.
If the information requested by this letter is information
required to be given to ASX under listing rule 3.1 your
obligation is to disclose the information immediately.
Your responsibility under listing rule 3.1 is not confined
to, or necessarily satisfied by, answering the questions set
out in this letter.
Trading halt
If you are unable to respond by the time requested, or if the
answer to question 1 is yes and an announcement cannot be
made immediately, you should consider a request for a trading
halt in the Group's securities. As set out in listing rule
17.1 and Guidance Note 16 - Trading Halts, we may grant a
trading halt at your request. We may require the request to
be in writing. We are not required to act on your request.
You must tell us each of the following.
• 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.
• Any other information necessary to inform the market about
the trading halt, or that we ask for.
The trading halt cannot extend past the commencement of
normal trading on the second day after the day on which it is
granted. If a trading halt is requested and granted and you
are still unable to reply to this letter before the
commencement of trading, suspension from quotation would
normally be imposed by us from the commencement of trading if
not previously requested by you. The same applies if you have
requested a trading halt because you are unable to release
information to the market, and are still unable to do so
before the commencement of trading.
If you have any queries regarding any of the above, please
let me know. Yours sincerely
Sent by electronic means without signature
Darren Collins
Head of National Accounting Group/Senior Adviser, Listings