Response to ASX Price Query

Ms Barbara Lim
Adviser, Listings Compliance (Perth)
Australian Securities Exchange

Your ref: 58208

By email: ListingsCompliancePerth@asx.com.au

Dear Barbara,

Advanced Human Imaging Ltd - Response to ASX Price Query Letter

Advanced Human Imaging Ltd (‘AHI’ or ‘the Company’) refers to ASX’s price query letter dated 30 August 2022 and provides the following responses to the specific questions set out in that letter.

Capitalised terms which are defined in ASX’s query letter have the same meaning where used in this letter, unless specified otherwise.

1. Is AHI 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?

Yes

2. If the answer to question 1 is “yes”.

a) Is AHI relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? Please note that the recent trading in AHI’s securities would suggest to ASX that such information may have ceased to be confidential and therefore AHI 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.

At the time of receipt of ASX’s query letter on 30 August 2022, the Company was in the final stages of discussions in relation to the acquisition of Wellteq Digital Health Inc. (CSE: WTEQ) (OTCQB: WTEQF) (wellteq and wellteq Acquisition) which was announced to ASX on 2 September 2022.

At the time of receipt of ASX’s query letter on 30 August 2022, the wellteq Acquisition was confidential and incomplete, and the Company had not announced that information to ASX in reliance on Listing Rule 3.1A.

The Company believes the following matters may have had an impact on the Company’s share price and trading volumes referred to in ASX’s query letter:

• on 29 August 2022, AHI announced that it has executed a Master Services Agreement with Activate Health OÜ, a digital health provider that built the world’s first AI-driven digital therapeutics platform from metabolic syndrome;

• the appointment of Peter Goldstein as a non-executive director of AHI. Mr Goldstein has over 30 years of diverse and global entrepreneurial, client advisory and capital market experience; and

• the release of AHI’s 30 June 2022 Quarterly Activities Report on 29 July 2022, which provided updates to the market with respect to the integration of Vertica Health, Inter-Psy and Nextmedicall S.A.C’s (amongst others) technology with AHI’s technology.

The Company believes that confidentiality in relation to the wellteq Acquisition was maintained at all times up to the announcement of that transaction on 2 September 2022, and notes that wellteq shares (which trade on the Canadian Securities Exchange) did not experience any material change in trading price or volume during the period referred to in ASX’s query letter or while the Company’s shares have been in trading halt.

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).

As noted above, the wellteq Acquisition was announced to ASX on 2 September 2022.

c) If an announcement cannot be made immediately, why not and when is it expected that an announcement will be made?

As noted above, the wellteq Acquisition was announced to ASX on 2 September 2022.

3. If the answer to question 1 is “no”, is there any other explanation that AHI may have for the recent trading in its securities?

Not applicable.

4. Please confirm that AHI is complying with the Listing Rules and, in particular, Listing Rule 3.1.

The Directors of AHI confirm that the Company is complying with the ASX Listing Rules, in particular ASX Listing Rule 3.1.

5. Please confirm that AHI’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 AHI with delegated authority from the board to respond to ASX on disclosure matters.

AHI confirms that the 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 AHI with delegated authority from the Board to respond to ASX on disclosure matters.

Should you require any further clarification, please do not hesitate to contact us.

Yours sincerely,

Simon Durack
Company Secretary & Chief Financial Officer
Advanced Human Imaging Ltd




30 August 2022
Reference: 58208

Mr Simon Durack
Company Secretary
Advanced Human Imaging Ltd

By email

Dear Mr Durack

Advanced Human Imaging Ltd (‘AHI’): Price - Query

ASX refers to the following:

A. The change in the price of AHI’s securities from $0.125 at the close of trade on 29 August 2022 to an intraday high of $0.245 today.

B. The significant increase in the volume of AHI’s securities traded today.

Request for information

In light of this, ASX asks AHI to respond separately to each of the following questions and requests for information:

1. Is AHI 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 AHI relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1? Please note that the recent trading in AHI’s securities would suggest to ASX that such information may have ceased to be confidential and therefore AHI 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 AHI may have for the recent trading in its securities?

4. Please confirm that AHI is complying with the Listing Rules and, in particular, Listing Rule 3.1.

5. Please confirm that AHI’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 AHI 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 11:30 AM AWST Tuesday, 30 August 2022. 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 2/2 ASX Customer Service Centre 131 279 | asx.com.au within the exceptions mentioned in Listing Rule 3.1A, AHI’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 AHI to request a trading halt immediately.


Your response should be sent to me by e-mail at ListingsCompliancePerth@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 AHI’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 AHI’s securities under Listing Rule 17.3.

Listing Rules 3.1 and 3.1A

In responding to this letter, you should have regard to AHI’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 AHI’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

We reserve the right to release a copy of this letter, your reply and any other related correspondence between us to the market under Listing Rule 18.7A.

Questions

If you have any questions in relation to the above, please do not hesitate to contact me.

Yours sincerely
Barbara Lim
Adviser, Listings Compliance (Perth)