Continuous Disclosure Policy

Continuous Disclosure Policy

  • Summarises the company's disclosure obligations
  • Explains the type of information requiring disclosure
  • Identifies who is responsible for the disclosure
  • Explains how individuals can successfully implement the policy.

Policy Summary

The company's main continuous disclosure obligations are set out in ASX Listing Rules 3.1 and 3.1B and section 674 of the Corporations Act. The general rule, in accordance with ASX Listing Rule 3.1, is that once a company becomes aware of any information concerning it that a reasonable person would expect to have a material effect on the price or value of the entity's securities, the entity must immediately notify the ASX of that information.

The company has established a Disclosure Committee which is responsible for:

  • ensuring the company complies with its disclosure obligations
  • determining what information can or should be disclosed to the market
  • overseeing and coordinating the disclosure of information to the ASX, shareholders, analysts, stockbrokers, media and the public
  • educating officers and employees on the company's continuous disclosure policy and procedures and raising awareness of the principles underlying continuous disclosure.

The committee is also responsible for:

  • delegating responsibilities to other company officers and employees, as it considers appropriate
  • appointing a disclosure officer for the purposes of liaising with the ASX regarding the company's Listing Rules obligations.

The company has established written policies and procedures to ensure compliance with its continuous disclosure obligations. In summary the company adheres to the following practices:

The company must immediately notify the ASX of any undisclosed price-sensitive information in accordance with the company's legislative and regulatory disclosure obligations and the procedures set out in this policy.

If the company becomes aware that information that should be released to the ASX has become generally available or is available to a sector of the market, and that information has not been given to the ASX, the company must immediately give the information to the ASX.

Disclosure of price-sensitive information to the ASX must be made by the company acting through the committee or an appointed disclosure officer in accordance with the method of disclosure prescribed by the ASX.

The company must not publicly disclose price-sensitive information until it has given that information to the ASX and has received an acknowledgment from the ASX that the information has been released to the market.

After an acknowledgment has been received from the ASX, information disclosed in compliance with this policy is promptly placed on the company's website.

The committee may also determine that the disclosed information should be released to major news services and other news outlets.

The number of authorised spokespersons of the company is kept to a minimum to avoid inconsistent communications and reduce the risk of material information being inadvertently disclosed to the market.

The Policy details the procedures for responding to market rumours, dealing with analyst, shareholder and investor queries, commenting on analyst reports and forecasts and requesting trading halts.