ASX compliance query expands as Unity Metals finds third missed notice

Three Directors Caught in Late Disclosure Review

Unity Metals Limited (ASX:UM1) has uncovered a third missed director interest notice after ASX questioned the delayed reporting of option expiries by Andrew Wright and Craig Mackay. The company said the three directors held a combined 1.14 million unlisted options that expired unexercised on 31 May 2026, with no trading or payment involved.

Wright’s 1.1 million options and Mackay’s 20,000 options were exercisable at US$0.25. Their Appendix 3Y notices were not lodged until 27 October, more than four months after the five-business-day reporting window identified by ASX. During its follow-up review, Unity Metals found that Gilbert Rodgers also held 20,000 options with the same expiry date and lodged his notice alongside its response.

ASX Raises Possible Listing Rule Breaches

ASX had warned that the delays may have breached Listing Rules 3.19A and 3.19B, which require listed companies to report changes in directors’ notifiable interests and maintain arrangements to ensure those disclosures are made on time. The exchange also said the directors may have breached section 205G of the Corporations Act.

Unity Metals attributed the delay to an administrative oversight. It said the option expiry was automatic, rather than the result of a dealing by the directors, and was missed during the company’s monitoring of director holdings. The oversight was identified on 26 October while the company reviewed interests following the October share purchase plan, which had targeted $1 million for exploration funding.

The company said it had not previously lodged an Appendix 3Y late and described the matter as isolated. The discovery of a further missed notice, however, means the review identified the same reporting gap across three directors rather than two. The filing does not say whether ASX will take enforcement action or impose a penalty.

New Controls Target Option Expiry Dates

Unity Metals said directors already had contractual duties to notify the company secretary of changes in their interests, alongside a securities trading policy and company secretary oversight. It has nevertheless added a securities calendar covering expiry, vesting and conversion dates, with reminders set 10 business days ahead of each event.

Director holdings will also be reconciled monthly against the company’s share and option registers, while directors will confirm their interests at each board meeting. The board is due to consider the review at its next meeting, leaving the effectiveness of the new controls, and ASX’s response to the delayed filings, as the next regulatory questions for UM1 shareholders.