FCA Complaint - Case Ref #205882095

Bushveld Shareholders Association

16 April 2019

Dear Sirs,

we are writing in reference to the ongoing case ref 205882095 (Bushveld Minerals) - since the 8th of April 2019 it has become apparent that there have been regular systematic sequences of trading designed to reduce the share price of this security (LSE:BMN) - this would appear to be a very clear example of Market Manipulation to drive the share price down so as to financially benefit those that have made, and continue to make, short sells or short spreadbets on this stock.

The unusual trading in the week of 8th-12th April is described in the related article here, this letter adds to this by describing the trading of Monday the 15th April 2019 which appears to fit the same patterns of manipulation but which takes the manipulation to a level of excess which demands immediate investigation so as to maintain the integrity of the markets.

We have reason to believe that these trades are being made by a network of individuals that are undertaking a coordinated program of shorting and market manipulation. This network is based within the UK, primarily in the midlands and further details can be provided upon request.

The overall pattern of trades for the 15th of April 2019 is shown below with trades allocated (Buys or Sells by Private Investors) by individual inspection. Bed & ISA requests are easily separable from the general mass of trades thus allowing an accurate nett trading position to be established and trades larger than the Minimum Market Size (30,000) have also been highlighted.

The manipulative trading activity we believe should be investigated falls into two time periods as indicated on the chart.

Period A shows evidence of rapidly repeated selling at or above the MMS (30K or 50K shares) at integer Bid prices (eg 31.0, 30.0, 29.0p) until the Bid price is dropped. The same type of behaviour has been observed multiple times (at 32.0p, 31.0p)  in previous days (referred to in the aforementioned analysis of the previous weeks trading as 'Mr Round-number').

The trades marked in red below, we believe deserve further investigation to establish if they originate from within the same coordination network referred to above.

Period B shows precisely the same pattern between 16:17 and 16:18 which also resulted in the Bid price being dropped. This pattern is observed in the middle of a more extensive period of exceptionally aggressive selling, seemingly timed so as to inflict maximum negative impact on the share price before the end of the trading day, and to reduce the share price to sub-30p levels that have been openly advertised as a target by those who we believe to be part of this coordination network.

The trades marked in red below, we believe deserve further investigation to establish if they originate from within the same coordination network referred to above.

The fair operation of UK share markets is vital to maintaining their operational integrity - private investors will simply avoid all and any markets which appear to be so easily gamed by the coordinated manipulation that appears to be being undertaken here.

We look forward to your response to this complaint and remain on hand to assist with any questions that you have relevant to your investigation.

Yours sincerely,

Bushveld Shareholders Association

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