Dealing with analysts. The Company must ensure that it does not give analysts any material price sensitive non public information at any time, for example, during analysts' briefings, answering analysts questions or reviewing draft analyst research reports. Where possible, the Company will arrange for advance notice of significant group briefings and will use reasonable endeavours to make them as widely accessible as possible (including through the use of webcasting or any other mass communication mechanism as may be practical. It is permissible to clarify or correct any errors of interpretation that analysts make concerning already publicly available information, but only to the extent that the clarification or correction does not itself amount to giving material non publicly available information (such as correcting market expectations about profit forecasts). In order to increase transparency and confidence in the Company's disclosure practices, all information given to analysts at a briefing, such as presentation slides, is to be given to the Company Secretary for immediate release to the ASX and posted on the Company's website. The information must always be released to ASX first. Slides from other public speeches, such as at an industry seminar, should also be made available in this way. Ideally, all dealings with analysts should be carefully monitored by the Company to ensure that material non public information was not inadvertently disclosed, and if it was, to immediately disclose that information to ASX. Monitoring can occur by audio recording of the dealing, taking detailed notes of the conversations or having a person in the room where the sole role is to observe proceedings and lookout for any material non public disclosures. The Company will maintain (for internal purposes) a summary record of issues discussed at group or one-to-one briefings with investors and analysts, including lists of who was present as well as the time and place of the meeting.
Dealing with analysts. The Company must ensure that it does not give analysts any material price sensitive non public information at any time (e.g. during analysts' briefings, answering analysts questions or reviewing draft analyst research reports). Where possible, the Company will provide advance notice of significant group briefings and will use reasonable endeavours to make them as widely accessible as possible (including through the use of webcasting, or publishing recordings or transcripts on the Company's website). When responding to enquiries or correcting errors from analysts, the Company must be careful not to inadvertently provide analysts with material non-public information (e.g. inadvertently releasing financial information by correcting an analyst's profit forecasts). In order to increase transparency and confidence in the Company's disclosure practices, all information to be given to analysts at a briefing (such as presentation slides) must first be given to the Company Secretary for release to the ASX. The Company will carefully monitor all dealings with analysts to ensure that material non- public information is not inadvertently disclosed, and if it is, to immediately disclose that information to ASX. This may include audio recordings of dealings, the taking of detailed notes of conversations or having a designated person to observe proceedings with analysts. The Company will maintain an internal record of briefings with investors and analysts, (including details on the time and place, as well as a list of attendees).
