Approved by the Board on 27 February 2023
In accordance with the ASX Listing Rules, the Company will immediately notify the ASX of information:
concerning the Company that a reasonable person would expect to have a material effect on the price or value of the Company's securities, and
that would, or would be likely to, influence persons who commonly invest in securities in deciding whether to acquire or dispose of the Company's securities.
The only exception to this is where the ASX Listing Rules do not require such information to be disclosed.
Where appropriate, the Company will request a trading halt from the ASX to prevent trading in the Company's securities by an inefficient and uninformed market until the Company can make an announcement to the market.
Upon confirmation of receipt from the ASX, the Company will post all information disclosed in accordance with this policy on the Company's website in an area accessible by the public.
Internal notification and decision-making concerning the disclosure obligation The Board has designated the Managing Director or CEO as the person responsible for
overseeing and coordinating disclosure of information to the ASX as well as communicating with the ASX. The Managing Director or CEO and the Company Secretary will be responsible for ensuring that Company announcements are made in a timely manner, and will establish a vetting procedure to ensure that the announcements are factual and do not omit any material information. The Managing Director or CEO and Company Secretary will also ensure that Company announcements are expressed in a clear and objective manner that allows investors to assess the impact of the information when making investment decisions.
Measures for seeking to avoid the emergence of a false market in the Company's securities
The Company recognises that a false market in the Company's securities may result if the Company provides incomplete information to the ASX or if the Company fails to respond to market and media speculation that may, or may be likely to, have an impact on the price of the Company's securities.
While the Company does not, in general, respond to market speculation or rumours unless required to do so by law or the ASX, the Company is committed to disclosing as much information as possible, without harming the Company, to a wide audience of investors through media releases of important milestones, including information that may not strictly be required under continuous disclosure requirements. Information given to the ASX for market release will also be provided to investors through media releases. Such media releases will be posted on the Company's website.
Media contact and comment
The Board has designated the Managing Director or CEO (where appropriate) to speak to the press on matters associated with the Company. In speaking to the press, the Managing Director or CEO will not comment on price sensitive information that has not already been disclosed to ASX, however, they may clarify previously released information.
There will be times when Directors and employees will be approached by the media for public comment. On such occasions, the Director(s) or employee(s) should comply with the following:
refer the person to the Managing Director or CEO as appropriate for comment;
refrain from disclosing any information, documents or other forms of data to the person without the prior consent of the Managing Director or CEO;
report the person who contacted the Director/employee, the reason (explicit or inferred) for the contact and a summary of any other relevant information as soon as possible to the Managing Director or CEO.
External communications including analyst briefings and responses to shareholder questions
The Company discloses its financial and operational results to the market each half year/quarter as well as informing the market of other events throughout the year as they occur. Quarterly financial reports, media releases and AGM speeches are all lodged with the ASX and subsequently posted to the Company's website. As all financial information is disclosed through the ASX, the Company will only comment on factual errors in information and underlying assumptions when commenting on market analysts' financial projections, rather than commenting on the projections themselves.
In addition to the above disclosures, the Company does conduct briefings and discussions with the investing community. However, price sensitive information will not be discussed unless that information has been formally disclosed to the market via an ASX announcement. Slides and presentations used in briefings will also be released immediately prior to the briefing to the market via the ASX and posted on the Company's website.
Similarly, when answering shareholder questions, price sensitive information will not be discussed unless that information has been formally disclosed to the market via an ASX announcement.
Where a question can only be answered by disclosing price sensitive information, the Company will decline to answer it or take it on notice and announce the information to ASX prior to responding.
If any new price sensitive information is to be used in briefing media, institutional investors, and analysts or in answering shareholder queries, written materials containing such information will be lodged with the ASX prior to the briefing commencing. These briefing materials may also include information that may not strictly be required under continuous disclosure requirements. The briefing material will be posted to the Company's website as soon as the ASX confirms that this information has been received.