Response to ASX Price Query
Released
Released
Announcement PDF
24 September 2025
Ms. Yulia Gurdina
ASX Compliance Pty Limited
Level 6, 20 Bridge Street,
Sydney NSW 2000
Delivered via email: yulia.gurdina@asx.com.au
Dear Yulia,
RESPONSE TO PRICE QUERY
In reference to your letter of 24 September 2025, regarding the price and volume of the Company's
securities, the response to your queries in number order is as follows:
1. The Company is not aware of any price sensitive information that has not been announced, which
is an explanation for the recent trading in its securities.
2. Not Applicable.
3. The Company recently received a purchase order for the supply 65,000 HIV Self Test Kits destined
for Ukraine and funded by USAID. The estimated revenue from the Purchase order is below the
Company’s materiality threshold of $300,000 and hence the Company does not consider this to
be material information under its continuous disclosure obligations and as such did not announce
on the ASX Market Announcements Platform.
The Company however communicated the receipt of this purchase order through its investor
relations channels.
4. It is confirmed that the Company is in compliance with the disclosure provisions of the Listing
Rules, and in particular Listing Rule 3.1.
5. It is confirmed that the responses to the questions above have been authorised and approved by
the Board of the Company.
Please contact me if you require any further information concerning this matter.
Yours sincerely,
Mathew Watkins
Company Secretary
Atomo Diagnostics Limited
ACN 142 925 684
Level 1, 3-5 George St Leichhardt NSW 2040
24 September 2025
Reference: 112996
Mr Mathew Watkins
Company Secretary
Atomo Diagnostics Limited
Level 1, 3-5 George Street
LEICHHARDT NSW 2040
By email
Dear Mr Watkins
Atomo Diagnostics Limited (‘AT1’): Price Query
ASX refers to the following:
A. The change in the price of AT1’s securities from a low of $0.022 on 23 September 2025 to an intraday high
of $0.030 today, 24 September 2025.
B. The significant increase in the volume of AT1’s securities traded today, 24 September 2025.
Request for information
In light of this, ASX asks AT1 to respond separately to each of the following questions and requests for
information:
1. Is AT1 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 AT1 relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1?
Please note that the recent trading in AT1’s securities would suggest to ASX that such information
may have ceased to be confidential and therefore AT1 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 AT1 may have for the recent trading
in its securities?
4. Please confirm that AT1 is complying with the Listing Rules and, in particular, Listing Rule 3.1.
5. Please confirm that AT1’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 AT1 with delegated
authority from the board to respond to ASX on disclosure matters.
ASX Limited [[Listings]]
#10973373v1
ASX Customer Service Centre 131 279 | asx.com.au
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 3:00 PM AEST on Wednesday, 24 September 2025. 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, AT1’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 AT1 to request a trading halt immediately.
Your response should be sent to me by e-mail at ListingsComplianceSydney@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.
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 AT1’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 AT1’s
securities under Listing Rule 17.3.
Listing Rules 3.1 and 3.1A
In responding to this letter, you should have regard to AT1’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 AT1’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
ASX reserves the right to release all or any part of this letter, your reply and any other related correspondence
between us to the market under Listing Rule 18.7A.
Regards
ASX Compliance
2/2
ASX Customer Service Centre 131 279 | asx.com.au
#10973373v1
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