Corporate Governance Statement 2026
Released
Released
Announcement PDF
Corporate Governance Statement
Approved by the board of directors and issued on 25 September 2026
Corporate Governance Statement
Litchfield Minerals Limited (‘the Company’) is committed to implementing the highest standards of corporate governance. In determining what those high
standards should involve the Company has turned to the ASX Corporate Governance Council’s Corporate Governance Principles and Recommendations, 4th Edition.
Where the Company does not have certain policies or committees recommended by the ASX Corporate Governance Council (‘the Council’) in place during the
reporting period, we have identified such policies or committees. The Board of Directors of Litchfield Minerals Limited (‘the Board’) are responsible for corporate
governance of the Company. The Board guides and monitors the business and affairs of the Company on behalf of the shareholders by whom they are elected and
to whom they are accountable. Where the Company’s corporate governance practices do not correlate with the practices recommended by the Council, the
Company is working towards compliance, however it does not consider that all the practices are appropriate for the Company due to the size, nature and scope of
Company operations. As the Company’s activities develop in size, nature and scope, the size of the Board and the implementation of additional corporate
governance policies and structures will be reviewed.
This statement and information identified therein is available on the company’s website at www.litchfieldminerals.com.au under the Corporate Governance tab in
the Corporate section.
Date of last review and Board approval: 25 September 2026
PRINCIPLE 1 – LAY SOLID FOUNDATIONS FOR MANAGEMENT AND OVERSIGHT
Recommendation Compliance Reference Commentary
1.1
A listed entity should have and disclose a
board charter setting out:
(a) the respective roles and
responsibilities of its board and
management; and
(b) those matters expressly reserved to
the board and those delegated to
management.
Yes Board
Charter -
Website
The Company has established the functions reserved to the Board, and those delegated to senior
executives and the Company Secretary and has set out these functions in its Board Charter.
The Board of Litchfield Minerals is responsible for, and oversees the governance of, Litchfield
Minerals. The Board develops strategies for the Company, reviews strategic objectives and monitors
performance against those objectives. Clearly articulating the division of responsibilities between the
Board and management
will help manage expectations and avoid misunderstandings about their respective roles and
accountabilities. In general, the Board assumes (amongst others) the following responsibilities.
• reviewing and approving its strategies, budgets and business plans
• overseeing management in its implementation of Litchfield Minerals’ strategic objectives, its
role in instilling Litchfield Minerals’ values and performance generally
• approving Litchfield Minerals’ Values Statement and Code of Conduct to underpin a culture of
acting lawfully, ethically and responsibly
• satisfying itself that Litchfield Minerals has in place an appropriate risk management
framework (for both financial and non-financial risks including climate change risk) and
setting the risk appetite within which the Board expects management to operate
• satisfying itself that Litchfield Minerals’ remuneration policies are aligned with its purpose,
values, strategic objectives and risk appetite
1.2
A listed entity should:
(a) undertake appropriate checks
before appointing a director or
senior executive or putting someone
forward for election as a director;
and
(b) provide security holders with all
material information in its
possession relevant to a decision on
whether or not to elect or re-elect a
director.
Yes Board
Charter -
Website
Litchfield Minerals aims to have a board of directors that has, at all times, the appropriate mix of skills,
experience, expertise and diversity relevant to Litchfield Minerals’ businesses and the Board’s duties
and responsibilities. With guidance from external consultants where necessary, the Board will identify
candidates with appropriate skills, experience, expertise and diversity in order to discharge its
mandate effectively and to maintain the necessary mix of expertise on the Board. The Board will
assess nominations of new directors against a range of criteria including the candidate’s background,
experience, gender, professional skills, personal qualities and whether their skills and experience will
complement the existing Board.
All directors (other than a managing director) are subject to re-election by rotation at least every three
years subject to being nominated by the Board. Newly appointed directors must seek re-election at
the first general meeting of shareholders following their appointment. For shareholder meetings
where directors are standing for election or re-election, the notice of meeting will include information
to enable shareholders to make an informed decision on their election.
1.3
A listed entity should have a written
agreement with each director and senior
executive setting out the terms of their
appointment.
Yes Board
Charter -
Website
Written agreements are in place with each director and senior executive for the full year.
New directors are to be provided with a formal letter of appointment to the Board setting out the key
terms and conditions of the appointment, together with any other documents that Litchfield Minerals
considers relevant to the appointment.
Recommendation Compliance Reference Commentary
Recommendation 1.4
The company secretary of a listed entity
should be accountable directly to the
board, through the chair, on all matters to
do with the proper functioning of the
board.
Yes Board
Charter -
Website
The Company has established the functions reserved to the Board, and those delegated to the
Company Secretary and has set out these functions in its Board Charter.
Recommendation 1.5
A listed entity should:
(a) have and disclose a diversity policy;
(b) through its board or a committee of
the board set measurable objectives
for achieving gender diversity in the
composition of its board, senior
executives and workforce generally;
and
(c) disclose in relation to each reporting
period:
(1) the measurable objectives set
for that period to achieve
gender diversity;
(2) the entity’s progress towards
achieving those objectives; and
(3) either:
(A) the respective proportions
of men and women on the
board, in senior executive
positions and across the
whole workforce (including
how the entity has defined
“senior executive” for these
purposes); or
(B) if the entity is a “relevant
employer” under the
Workplace Gender Equality
Act, the entity’s most
recent “Gender Equality
Indicators”, as defined in
No Diversity
Policy -
Website
The Board values diversity (in its broader sense) and recognises the benefits it can bring to the
organisation's ability to achieve its goals. However, given the current stage of the Company's
operations and number of employees, the Company has determined at this stage not to formally adopt
a diversity policy. The Company will re-assess this as the Company grows.
Diversity includes, but is not limited to, gender, age, disability, ethnicity, marital or family status,
religious beliefs, socio-economic background, perspective, experience, cultural background, sexual
orientation and gender identity. The Company is committed to diversity and recognises the benefits
arising from employee and board diversity and the importance of benefiting from all available talent.
The Board has adopted a policy to address harassment and discrimination in the Company, which it
believes will facilitate an environment that encourages a diverse workforce.
As at the date of this report, the Company has the following proportion of women appointed:
• to the Board – 0%
• to senior management – 0%
• to the organisation as a whole – 0%
The Company recognises that the mining and exploration industry is intrinsically male dominated in
many of the operational sectors and the pool of women with appropriate skills will be limited in some
instances. Where possible, the Company will seek to identify suitable candidates for positions from a
diverse pool.
Recommendation Compliance Reference Commentary
and published under that
Act.
If the entity was in the S&P / ASX 300
Index at the commencement of the
reporting period, the measurable
objective for achieving gender diversity in
the composition of its board should be to
have not less than 30% of its directors of
each gender within a specified period.
Recommendation 1.6
A listed entity should:
(a) have and disclose a process for
periodically evaluating the
performance of the board, its
committees and individual
directors; and
(b) disclose for each reporting period
whether a performance evaluation
has been undertaken in accordance
with that process during or in
respect of that period.
Yes Board
Charter -
Website
The Chairman is responsible for evaluating the performance of the Board and, when appropriate,
Board committees and individual directors deemed. A Non-Executive Director is responsible for
evaluating the Chairman. The evaluations of the Board, and any applicable Board committees and
individual directors are undertaken via informal discussions on an ongoing basis with the Chairman.
The evaluation of the Managing Director is undertaken via an informal interview process which occurs
annually or more frequently, at the Board’s discretion.
The evaluation of the non-executive Directors is undertaken via an informal interview process which
occurs annually or more frequently, at the Board’s discretion.
Recommendation 1.7
A listed entity should:
(a) have and disclose a process for
evaluating the performance of its
senior executives at least once
every reporting period; and
(b) disclose for each reporting period
whether a performance evaluation
has been undertaken in accordance
with that process during or in
respect of that period.
Yes Board
Charter -
Website
The Managing Director is responsible for evaluating the performance of senior executives. The
evaluation of senior executives is undertaken via an informal interview process which occurs annually
or more frequently as required and otherwise takes place as part of the annual salary review under the
senior executives’ employment contract.
During the financial year, informal evaluations have occurred on a number of times.
PRINCIPLE 2 - STRUCTURE THE BOARD TO BE EFFECTIVE AND ADD VALUE
Recommendation Compliance Reference Commentary
Recommendation 2.1
The board of a listed entity should:
(a) have a nomination committee
which:
1) has at least three members, a
majority of whom are
independent directors; and
2) is chaired by an independent
director,
and disclose:
3) the charter of the committee;
4) the members of the
committee; and
5) as at the end of each reporting
period, the number of times the
committee met throughout the
period and the individual
attendances of the members at
those meetings; or
(b) if it does not have a nomination
committee, disclose that fact and
the processes it employs to address
board succession issues and to
ensure that the board has the
appropriate balance of skills,
knowledge, experience,
independence and diversity to
enable it to discharge its duties and
responsibilities effectively.
No People &
Remuneratio
n Committee
Charter
Board
Charter
Annual
Report
Website
The Company does not have a Nomination and Remuneration Committee. The Board is of the opinion
that due to the nature and size of the Company, the functions performed by a Nomination and
Remuneration Committee can be adequately handled by the full Board. At such time when the
Company is of sufficient size, a separate Nomination and Remuneration Committee will be formed.
When the Board convenes to carry out the functions performed by a Nomination and Remuneration
Committee, it carries out those functions set out in the Company’s Nomination and Remuneration
Committee Charter. The Company has adopted a Nomination and Remuneration Committee Charter
which describes the role, composition, functions and responsibilities of the Nomination and
Remuneration Committee.
In determining candidates for the Board, the Nomination and Remuneration Committee (or equivalent)
follows a prescribed process whereby it evaluates the mix of skills, experience and expertise of the
existing Board. In particular, the Nomination and Remuneration Committee (or equivalent) is to
identify the particular skills that will best increase the Board's effectiveness. Consideration is also
given to the balance of independent directors. Potential candidates are identified and, if relevant, the
Nomination and Remuneration Committee (or equivalent) recommends an appropriate candidate for
appointment to the Board. Any appointment made by the Board is subject to ratification by
shareholders at the next annual general meeting.
The Board recognises that Board renewal is critical to performance and the impact of Board tenure on
succession planning. Each director other than the Managing Director, must not hold office (without re-
election) past the third annual general meeting of the Company following the director's appointment
or three years following that director's last election or appointment (whichever is the longer). However,
a director appointed to fill a casual vacancy or as an addition to the Board must not hold office (without
re-election) past the next annual general meeting of the Company. At each annual general meeting a
minimum of one director or one third of the total number of directors must resign. A director who
retires at an annual general meeting is eligible for re-election at that meeting and re-appointment of
directors is not automatic.
Recommendation 2.2
A listed entity should have and disclose a
board skills matrix setting out the mix of
skills that the board currently has or is
looking to achieve in its membership.
No Website The Board does not maintain a formal Board Skills Matrix, as the Board considers that such a matrix
is not necessary given the current size and scope of the Company’s operations.
The Board may adopt such a matrix at a later time as the Company’s operations grow and evolve.
Recommendation 2.3
A listed entity should disclose:
Yes Board
Charter
The Board considers the independence of directors having regard to the relationships listed in Box
2.3 of the Principles & Recommendations and the Company's materiality thresholds. When
considering whether a director is an independent director, the materiality of an interest, position,
Recommendation Compliance Reference Commentary
(a) the names of the directors
considered by the board to be
independent directors;
(b) if a director has an interest,
position, affiliation or relationship of
the type described in Box 2.3 but the
board is of the opinion that it does
not compromise the independence
of the director, the nature of the
interest, position or relationship in
question and an explanation of why
the board is of that opinion; and
(c) the length of service of each
director.
Annual
Report
Website
association or relationship must be assessed to determine whether it might interfere, or might
reasonably be perceived to interfere, in a material respect, with the director’s capacity to bring an
independent judgement to bear on issues before the Board and to act in the best interests of the
Company and its shareholders. Directors have been selected to bring specific skills and industry
experience to the Company. The Board has an expansive range of relevant industry experience,
financial, legal and other skills and expertise to meeting its objectives.
Director Assessment
Dr Peter Eaglen (Non-Executive Chairman), including entities associated with him, is an
(approximately) 2.27% shareholder in the Company. He has also received performance-based
remuneration from the Company (Options and Performance Rights). Dr Eaglen’s independence has
been assessed by the Board and is considered by the Board to be independent.
Professor Mark Noppé (Non-Executive Director), including entities associated with him, is an
(approximately) 1.03% shareholder in the Company. He has also received performance-based
remuneration from the Company (Options and Performance Rights). Professor Noppé’s
independence has been assessed by the Board and is considered by the Board to be independent.
Mr Matthew Pustahya (Managing Director), holds and executive position in the Company and including
entities associated with him, is an (approximately) 9.2% shareholder in the Company. Mr Pustahya is
therefore not considered by the Board to be independent.
The length of service of each director is disclosed in the Company’s Annual Report.
Recommendation 2.4
A majority of the board of a listed entity
should be independent directors.
Yes Independenc
e of Directors
Assessment
Website
As noted above, two of the three directors of the Company are independent and meet the
requirement of recommendation 2.4.
Recommendation 2.5
The chair of the board of a listed entity
should be an independent director and, in
particular, should not be the same person
as the CEO of the entity.
Yes Independenc
e of Directors
Assessment
Website
The chair of the Board, Dr Eaglen was assessed as an independent director and is not the CEO of the
Company and meets recommendation 2.5.
Recommendation 2.6
A listed entity should have a program for
inducting new directors and for
periodically reviewing whether there is a
need for existing directors to undertake
professional development to maintain the
Yes Board
Charter
Website
It is the policy of the Company that each new Director undergoes an induction process in which they
are given a full briefing on the Company. Where possible this includes meetings with key executives,
tours of the premises, an induction package and presentations.
Information conveyed to new Directors include:
• details of the roles and responsibilities of a Director;
Recommendation Compliance Reference Commentary
skills and knowledge needed to perform
their role as directors effectively.
• formal policies on Director appointment as well as conduct and contribution expectations;
• a copy of the Corporate Governance Statement, Charters, Policies and Memos; and
• a copy of the Constitution of the Company.
In order to achieve continuing improvement in Board performance, all Directors are encouraged to
undergo continual professional development
PRINCIPLE 3 – INSTIL A CULTURE OF ACTING LAWFULLY, ETHICALLY AND RESPONSIBLY
Recommendation Compliance Reference Commentary
Recommendation 3.1
A listed entity should articulate and
disclose its values
Yes Code of
Conduct -
website
The Company has established a code of conduct to support Litchfield Minerals’ Corporate Values
Statement and is a guide of the expected behaviours from all Employees to act in accordance with
Litchfield Minerals’ values and in the best interest of Litchfield Minerals.
Recommendation 3.2
A listed entity should:
(a) have and disclose a code of conduct
for its directors, senior executives
and employees; and
(b) ensure that the board or a
committee of the board is informed
of any material breaches of that
code.
Yes Code of
Conduct -
website
The Code of Conduct has been approved by the Company’s board of directors and sets out the way
Litchfield Minerals conducts business. Litchfield Minerals will carry on business honestly and fairly,
acting only in ways that reflect well on Litchfield Minerals in strict compliance with all laws and
regulations.
The purpose of this Code is to guide the behaviour of everyone in Litchfield Minerals (including all
employees, contractors, consultants, managers and directors, including temporary employees,
contractors and directors of Litchfield Minerals) by clearly stating Litchfield Minerals’ firm
commitment to behaving honestly and fairly.
The Code outlines the procedure for notifying the Board of any non-compliance of the Code.
Recommendation 3.3
A listed entity should:
(a) have and disclose a whistleblower
policy; and
(b) ensure that the board or a
committee of the board is informed
of any material incidents reported
under that policy.
Yes Whistleblowe
r Policy –
website
The Company has a Whistleblower Policy, within its Corporate Governance Plan, which is on the
Company’s website.
Recommendation 3.4
A listed entity should:
(a) have and disclose an anti-bribery
and corruption policy; and
(b) ensure that the board or committee
of the board is informed of any
material breaches of that policy.
Yes Anti-bribery
and
Corruption
Policy -
website
The Company has an Anti-bribery and Corruption Policy within its Corporate Governance Plan, which
is on the Company’s website.
PRINCIPLE 4 – SAFEGUARD THE INTEGRITY OF CORPORATE REPORTS
Recommendation Compliance Reference Commentary
Recommendation 4.1
The board of a listed entity should:
(a) have an audit committee which:
1) has at least three members, all
of whom are non-executive
directors and a majority of
whom are independent
directors; and
2) is chaired by an independent
director, who is not the chair of
the board,
and disclose:
3) the charter of the committee;
4) the relevant qualifications and
experience of the members of
the committee; and
5) in relation to each reporting
period, the number of times the
committee met throughout the
period and the individual
attendances of the members at
those meetings; or
(b) if it does not have an audit
committee, disclose that fact and
the processes it employs that
independently verify and safeguard
the integrity of its corporate
reporting, including the processes
for the appointment and removal of
the external auditor and the rotation
of the audit engagement partner.
No Audit & Risk
Management
Charter -
Website
The Company does not have an audit committee. The Board is of the opinion that due to the nature
and size of the Company, the functions performed by an audit committee can be adequately handled
by the full Board. At such time when the Company is of sufficient size, a separate Audit and Risk
Management Committee will be formed.
It is the Board’s responsibility to ensure that an effective internal control framework exists within the
entity. This includes both internal controls to deal with both the effectiveness and efficiency of
significant business processes, the safeguarding of assets, the maintenance of proper accounting
records, and the reliability of financial and non-financial information. It is the Board’s responsibility for
the establishment and maintenance of a framework of internal control of the Company.
The Company has established procedures for the selection, appointment and rotation of its external
auditor. The Board is responsible for the initial appointment of the external auditor and the
appointment of a new external auditor when any vacancy arises, as recommended by the Audit
Committee (or its equivalent). Candidates for the position of external auditor must demonstrate
complete independence from the Company through the engagement period. The Board may otherwise
select an external auditor based on criteria relevant to the Company's business and circumstances.
The performance of the external auditor is reviewed on an annual basis by the Audit Committee (or its
equivalent) and any recommendations are made to the Board.
Recommendation 4.2
The board of a listed entity should, before
it approves the entity’s financial
statements for a financial period, receive
from its CEO and CFO a declaration that,
in their opinion, the financial records of
Yes Kept at
registered
office
The Managing Director and the Chief Financial Officer provide a declaration to the Board in accordance
with section 295A of the Corporations Act for each financial report and assure the Board that such
declaration is founded on a sound system of risk management and internal control and that the system
is operating effectively in all material respects in relation to financial reporting risks. Such written
confirmations have been received in respect of the year under review.
Recommendation Compliance Reference Commentary
the entity have been properly maintained
and that the financial statements comply
with the appropriate accounting
standards and give a true and fair view of
the financial position and performance of
the entity and that the opinion has been
formed on the basis of a sound system of
risk management and internal control
which is operating effectively.
Recommendation 4.3
A listed entity should disclose its process
to verify the integrity of any periodic
corporate report it releases to the market
that is not audited or reviewed by an
external auditor.
Yes Kept at
registered
office
All periodic reports are reviewed and approved by the Board prior to public release.
PRINCIPLE 5 – MAKE TIMELY AND BALANCED DISCLOSURE
Recommendation Compliance Reference Commentary
Recommendation 5.1
A listed entity should have and disclose a
written policy for complying with its
continuous disclosure obligations under
listing rule 3.1.
Yes Continuous
Disclosure
Policy –
Website
The Company has established written policies and procedures designed to ensure compliance with
ASX Listing Rule disclosure requirements and accountability at a senior executive level for that
compliance.
Recommendation 5.2
A listed entity should ensure that its
board receives copies of all material
market announcements promptly after
they have been made.
Yes Continuous
Disclosure
Policy –
Website
All material announcements are reviewed and approved by the Board prior to release. Copies of all
announcements are kept at registered office.
Recommendation 5.3
A listed entity that gives a new and
substantive investor or analyst
presentation should release a copy of the
presentation materials on the ASX Market
Announcements Platform ahead of the
presentation.
Yes Continuous
Disclosure
Policy –
Website
All investor, conference or roadshow presentations are released on the ASX Market announcements
Platform ahead of the presentation.
PRINCIPLE 6 – RESPECT THE RIGHTS OF SECURITY HOLDERS
Recommendation Compliance Reference Commentary
Recommendation 6.1
A listed entity should provide information
about itself and its governance to
investors via its website.
Yes Corporate
Governance -
Website
The Company’s website includes the following:
• Corporate Governance policies, procedures, charters, programs, assessments, codes and
frameworks
• Names and biographical details of each of its directors
• Copies of annual, half yearly and quarterly reports within the ASX announcements
• ASX announcements
• Latest presentations
• Overview of the Company’s current projects
Recommendation 6.2
A listed entity should have an investor
relations program that facilitates
effective two-way communication with
investors.
Yes Shareholder
Communicatio
n Policy -
Website
The Company has designed a communications policy for promoting effective communication with
shareholders and encouraging shareholder participation at shareholder meetings.
Recommendation 6.3
A listed entity should disclose how it
facilitates and encourages participation
at meetings of security holders.
Yes Shareholder
Communicatio
n Policy -
Website
The Company has designed a communications policy for promoting effective communication with
shareholders and encouraging shareholder participation at shareholder meetings.
Recommendation 6.4
A listed entity should ensure that all
substantive resolutions at a meeting of
security holders are decided by a poll
rather than by a show of hands.
Yes N/A All resolutions at meetings of security holders are decided by poll.
Recommendation 6.5
A listed entity should give security
holders the option to receive
communications from, and send
communications to, the entity and its
security registry electronically.
Yes Shareholder
Communicatio
n Policy -
Website
Shareholders are regularly given the opportunity to receive communications electronically.
PRINCIPLE 7 – RECOGNISE AND MANAGE RISK
Recommendation Compliance Reference Commentary
Recommendation 7.1
The board of a listed entity should:
(a) have a committee or committees to
oversee risk, each of which:
1) has at least three members, a
majority of whom are
independent directors; and
2) is chaired by an independent
director,
and disclose:
3) the charter of the committee;
4) the members of the
committee; and
5) as at the end of each reporting
period, the number of times the
committee met throughout the
period and the individual
attendances of the members at
those meetings; or
(b) if it does not have a risk committee
or committees that satisfy (a) above,
disclose that fact and the processes
it employs for overseeing the entity’s
risk management framework.
No Audit & Risk
Management
Committee
Charter -
Website
The Company does not have a risk committee. The Board is of the opinion that due to the nature and
size of the Company, the functions performed by a risk committee can be adequately handled by the
full Board. At such time when the Company is of sufficient size, a separate Audit and Risk
Management Committee will be formed.
It is the Board’s responsibility to ensure that an effective internal control framework exists within the
entity. This includes both internal controls to deal with both the effectiveness and efficiency of
significant business processes, the safeguarding of assets, the maintenance of proper accounting
records, and the reliability of financial and non-financial information. It is the Board’s responsibility
for the establishment and maintenance of a framework of internal control of the Company.
The Board has adopted a Risk Management Policy to assist with the identification and review of risk
as well as the responsibilities within the Company.
Recommendation 7.2
The board or a committee of the board
should:
(a) review the entity’s risk management
framework at least annually to
satisfy itself that it continues to
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