Aim Regulation23 Jan 2024 20:15
Here's their reply to my complaint.
"Thank you for your email, copied below, regarding Shanta Gold Limited (the "Company") and the proposed acquisition of the Company by Saturn Resources Ltd, a wholly-owned subsidiary of ETC Holdings (Mauritius Limited), (the “proposed acquirer”).
AIM Regulation considers all enquiries as regards the conduct Thank you for your email, copied below, regarding Shanta Gold Limited (the "Company") and the proposed acquisition of the Company by Saturn Resources Ltd, a wholly-owned subsidiary of ETC Holdings (Mauritius Limited), (the “proposed acquirer”).
AIM Regulation considers all enquiries as regards the conduct of AIM companies and nominated advisers in respect of their compliance with the AIM Rules for Companies (“AIM Rules”) and for Nominated Advisers (“Nomad Rules”), and takes action where appropriate. Please note that AIM Regulation's remit does not extend beyond the AIM Rules and Nomad Rules. Further information regarding the remit of AIM Regulation, and that of other regulators and competent authorities, can be found at the following: AIM Regulatory Landscape.
We note your indication that, amongst other matters, you are dissatisfied with: (i) the proposed acquisition price per share which you suggest undervalues the Company; and (ii) the involvement and interest of one of the Company’s non-executive directors (Mr Ketan Patel) in the proposed acquirer; and (iii) the Company’s decision to recommend the acquisition to shareholders.
In this regard please note that agreeing the terms of a potential offer and a decision to recommend that shareholders accept it are primarily matters for the particular AIM company’s Board to consider, having regard to relevant legal duties and obligations. However, if you have not done so already, it may be of assistance to you to note that the Company has confirmed in its notification of 20 December 2023, amongst other matters, how it is managing conflicts through independent directors recommendations.
Further, you may wish to note that it is open to shareholders to vote against the proposal with, shareholder approval of the proposed acquisition conditional upon 75% majority shareholder resolutions. Further details of these arrangements and dates of the meetings will be included in the Scheme Document, due to be published in January 2024.
As indicated, we can assure you that we consider all enquiries and investigate alleged breaches of our rules. Accordingly, if you have specific concerns over the Company’s compliance with the AIM Rules or the nominated adviser’s compliance with the Nomad Rules please provide details to aimregulation@lseg.com. However, you will appreciate that confidentiality is essential in maintaining the integrity of our work and, accordingly, please note we are unable to comment on company specific matters.
We trust the above is of assistance to you.
Kind regards
AIM REGULATION"