PRINCIPLE 5: MAKE TIMELY AND BALANCED DISCLOSURE

Continuous disclosure
The company understands and respects that timely disclosure of price sensitive information is central to the efficient operation of the securities market and has adopted a comprehensive Market Disclosure Policy covering:

• announcements to the ASX;
• prevention of selective or inadvertent disclosure;
• conduct of investor and analysts briefings;
• media communications;
• commenting on expected earnings;
• communication black-out periods; and
• review of briefings and communications.
  

Under the Market Disclosure Policy, the Company Secretary, as the nominated disclosure officer, has responsibility for overseeing and co-ordinating the disclosure of information by the company to the ASX and for administering the policy and the group’s continuous disclosure education programme.

The Company Secretary, as the disclosure officer, is also responsible for referring matters to the Board’s disclosure committee. Matters referred to the disclosure committee, and decisions made by the committee, are recorded and referred to the Board at its next meeting. The disclosure committee is comprised of the Managing Director and the Finance Director.

The Market Disclosure Policy, and the associated training and education programme, is reviewed and monitored by the Audit Committee. Compliance with the policy is also monitored by the Board. The company’s Market Disclosure Policy is consistent with ASX Principle 5. A summary of the policy is available from the corporate governance section of the company’s website.

Additional company policies
In addition to the policies on market disclosure and share trading, the company has adopted a range of policies which have group wide application. These policies allow for the divisions to establish policies and procedures governing their own operations while seeking to ensure that a consistent approach and minimum acceptable standards are maintained across the group.