Continuous Disclosure Policy

ASX Listing Rule 3 deals with continuous disclosure for the timely provision of relevant price sensitive information to the ASX so that the market might be kept informed of events and developments as they occur.

Disclosure of Information to ASX

  • The Managing Director will coordinate and oversee all disclosure or announcements or releases to the market via the ASX.
     
  • All announcements or releases shall be released to the ASX prior to release to other third parties, brokers, analysts or media.
     
  • Wherever possible Directors and senior management shall inform the Company Secretary in advance (and wherever possible in a timely manner) of any information that might require disclosure to enable the Company Secretary to ascertain the Company’s obligations. Employees are not to determine whether information may be material but must pass on any information of which they become aware to the Company Secretary in order for him to ascertain whether it is to be disclosed.
     
  • Where any disclosure is required the Company Secretary shall refer the matter to the Managing Director for his prior approval. If the Managing Director is unavailable, the matter in his absence will be referred to an Executive Director or any Director if necessary.
     
  • The Company Secretary will be responsible for releasing information to the ASX. On its receipt by the ASX, the Company Secretary will ensure that it is disseminated to the directors and management promptly and that it be made accessible to the public as soon as possible.
     
  • In the event of inadvertent disclosure of information or knowledge of a deliberate leak, the Company Secretary should be informed in order to ascertain whether disclosure of the information to the ASX is required.
     
  • All material announcements to the ASX are to be posted to the Company’s Web Site which shall be periodically reviewed to ensure the accuracy and currency of material disclosed thereon.
     
  • Amendments to the Company’s Web Site may only be made with the approval of the Managing Director.
     
  • The Company has a policy that prevents Directors, Officers and employees from trading in securities of the Company without giving prior notice to the Company Secretary / the Chairman.
     
  • Further Directors, Officers and employees are prohibited from trading in any security of the Company:
    1. two weeks prior to and within 24 hours after the date of the announcement to the ASX of the Company’s annual or half year results;
    2. two weeks prior to and within 24 hours after the date of the announcement to the ASX of the Company’s quarterly activities reports;
    3. notwithstanding a) or b), at any time while in possession of inside information.
       

Disclosure to Media and Analysts

There should be no response to market speculation and rumours. If there is to be any comment to correct the media and market analysts’ projections, it should only occur after consideration has been given as to whether the information be provided in order to correct the errors is price sensitive and should be disclosed to the ASX. In any event such comment should be limited to correcting errors in factual information or assumptions made by the media and market analysts.
In any briefings to analysts or presentations to the media, any slides or other materials are to be approved beforehand by the Managing Director or in his absence the Company Secretary.

Clarifying information should only be given in any discussion following presentation at the briefing. If, in answering a question price sensitive information would be disclosed, then any answer to such a question should be declined or deferred for answer after consultation with the Managing Director or the Company Secretary.

Where possible, a review should to be held after any briefing to assess whether there might have been an inadvertent disclosure of price sensitive information. If so the matter is to be referred to the Company Secretary to ascertain whether disclosure to the ASX is required.

Company Spokesperson

Persons authorised to speak to analysts or the media on behalf of the Company are:

  • Chairman and Managing Director
  • Executive Directors
  • Company Secretary

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