Shareholder Communications Policy
Policy
The Code of Conduct requires the company and its employees to act with high standards of honesty, integrity, fairness and equity in all aspects of their employment.
With this in mind, the company commits to dealing fairly, transparently and openly with both current and prospective shareholders using available channels and technologies to reach widely and communicate promptly. The company commits to facilitating participation in shareholder meetings and dealing promptly with shareholder enquiries.
Our shareholder communication policy is built around compliance with disclosure obligations and aspiring to follow best practice in disclosure.
Our framework for communicating with shareholders is to concisely and accurately communicate:
- Regulatory risk
- our strategy;
- how we implement that strategy; and
- the financial results consequent upon our strategy and its implementation.
Continuous Disclosure
The continuous disclosure regime is fundamental to the rights of shareholders to receive information concerning their securities. The most important aspect of the company’s shareholder communication policy is to comply with the continuous disclosure regime and implement best practice disclosure policy.
Insider Trading
The insider trading rules are an important adjunct to the continuous disclosure regime in ensuring that shareholders are given fair access to material information regarding securities. The company seeks to limit the opportunity for insider trading in its own securities through its continuous disclosure policies and the dealing rules applying to its employees and directors.
Financial Reporting
Transparent and prompt financial reporting is a key element of listed company disclosure. The company reports operating results quarterly and produces half yearly and yearly financial reports and an annual report in accordance with the Corporations Act and listing rules.
The company aims to report promptly, comply with all applicable laws, listing rules and accounting standards in its financial reporting and to report in a way which is easy to understand and conveys the materiality of the matters discussed.
Shareholder Meetings
Shareholder meetings are an opportunity for shareholders and other guests to hear from and question the board and management.
The Chairman and Managing Director make presentations separately before attending to voting on resolutions and general business. The chair of the meeting, usually the Chairman, is responsible for the conduct of the meeting. The company auditor attends the annual general meeting and is available to answer any questions regarding the conduct of and any issues arising from the audit.
In the conduct of its shareholder meetings without attending in person the company accepts nominations for the Board that are made to the Company Secretary in accordance with the listing rules and the company’s constitution.
The company conducts annual and extraordinary general meetings in accordance with the Corporations Act, the Listing Rules, Corporate Governance Council guidelines and the company’s constitution.
The company drafts notices and proxy forms to maximise the ability of readers to understand and vote on the issues presented. The company will also investigate ways of using technology to simplify voting and to electronically distribute material regarding meetings.
Correspondance and Reports to Shareholders
The company corresponds periodically with all shareholders to update them on the company’s activities and progress. The correspondence is signed by the Chairman and may at times accompany dividend payment advice or cheques.
The company takes steps to identify and communicate with beneficial owners. Where they wish, beneficial owners may receive all materials that are sent to direct shareholders including email notifications, correspondence and notices of meeting.
General Interaction with Shareholders
The company deals with shareholder enquiries promptly and courteously and takes measures to ensure that its share registrar also does so.
Shareholder Privacy
The company recognises that privacy is important and will not disclose registered shareholder details unless required by law. Shareholder details will only be used in accordance with applicable privacy laws.