Continuous Disclosure Policy
The Australian Stock Exchange encourages listed entities to establish written policies and procedures for information disclosure, and to focus on continuous disclosure accessible by all investors. These policies set out the processes by which the Company can promptly identify and, if required, disclose relevant information to the market.
The following policies have been set out to ensure that the Company meets the obligations under listing rule 3, Continuous Disclosure:
1. Co-ordination of Disclosure of Information
The Company will appoint a senior officer to co-ordinate the disclosure of information to the Australian Stock Exchange, investors, shareholders, media and the public. The person appointed until further notice is the Company Secretary. In the absence of this person responsibility falls to the Managing Director.
Disclosure to the Australian Stock Exchange is only permitted with the approval of the Managing Director or Chairman.
2. Obligation to Disclose Price-Sensitive Information
Directors, Management and staff are required to bring any price-sensitive or material information to the attention of the Company Secretary as soon as they become aware of this information.
• Executive management must notify the Company Secretary of any price-sensitive information immediately
• Board resolutions must be notified to the Company Secretary immediately they are passed
The Company Secretary will consider and advise the Managing Director and/or Board as to whether the information should be disclosed to the Australian Stock Exchange.
The Company Secretary is responsible for monitoring compliance with the Continuous Disclosure policy.
3. Distribution of Company Announcements and Material Information
Company announcements will be disclosed first to Australian Stock Exchange before they are distributed to shareholders, brokers, the media or the public. Only the Company Secretary or designate is authorised to send disclosure to the Australian Stock Exchange on behalf of the Company, and a file of all such announcements will be maintained by him/her.
4. Access to Information by Investors
When the company has received acknowledgement from the Australian Stock Exchange that an announcement has been received by the market, the announcement will be posted to the Company Website as soon as possible and emailed to those investors who have elected to participate in the company’s announcement service.
5. Analyst and Private Briefings
Analysts, other investors or the media must not be provided with any material or price-sensitive information which is not already in the public domain. Should such information be inadvertently disclosed during such a briefing it must be brought to the attention of the Company Secretary immediately for consideration to disclose to the market. Where briefings are to be held in the absence of the Company Secretary, copies of information provided such as slides and handouts should be given to the Company Secretary.
Where analysts request confirmation of facts and figures in an analyst report to be released to investors, comments should be restricted to correcting factual errors and underlying assumptions only, not to providing sales or profit projections.
6. Market Speculation
The Company has a policy of not responding to market speculation and rumours. However, there may be times when it is necessary to release a statement or information, to ensure no false market exists in the company’s securities. The Company Secretary is responsible for determining the statement or information to be released.
7. Breaches of Policy
Employees are expected to strictly comply with the Continuous Disclosure Policy and breaches will be subject to disciplinary action, up to and including dismissal.