Alt Resources Ltd (‘the Company’) must continuously advise the ASX of information to keep the market informed of events and developments relating to the Company as they occur. If it does not, then there may be significant criminal and civil penalties imposed on the Company and its Officers.
This policy sets out the rules for disclosing information to the ASX, the obligations on the Company and its Officers and the procedures put in place by the Company to comply with the rule.
This policy is in addition to the rules the Company must comply with for routine disclosures to the ASX, such as quarterly and annual reporting.
Disclosure Obligations on the Company
Listing Rule 3.1 requires the Company to immediately disclose to the ASX any information concerning the Company that it is or becomes aware of, that a reasonable person would expect to have a material effect on the price or value of the Company’s securities.
This rule does not apply to particular information if, and only if, each of the following applies:
- a reasonable person would not expect the information to be disclosed;
- the information is confidential and the ASX has not formed a view that the information has ceased to be confidential; and
- one or more of the following applies:
a) it would be a breach of a law to disclose the information;
b) the information concerns an incomplete proposal or negotiation;
c) the information comprises matters of supposition or is insufficiently definite to warrant disclosure;
d) the information is generated for the internal management purposes of the Company;
e) the information is a trade secret.
If the ASX considers there is or is likely to be a false market in the Company’s securities, ASX may ask the Company to disclose information or make a statement to correct or prevent the false market. This may occur where there is market speculation or media reports arising from a leakage of confidential information concerning a proposal or negotiations that have not been disclosed by the Company because the exception to Listing Rule 3.1 applies.
The purpose of this policy is to ensure that Company announcements are:
- made in a timely manner;
- are factual;
- do not omit material information; and
- are expressed in a clear and objective manner that allows investors to assess the impact of the information when making investment decisions.
Continuous Disclosure Protocol – Commitment
The Company is committed to:
- ensuring that stakeholders have the opportunity to access externally available information issued by the Company;
- providing full and timely information to the market about the Company’s activities; and
- complying with the obligations contained in the Australian Securities Exchange Listing Rules and the Corporations Act relating to continuous disclosure.
Continuous Disclosure Policy
The Company has obligations under the Corporations Act and ASX Listing Rules to keep the market fully informed of information which may have a material effect on the price or value of Alt Resources securities, or influence an investment decision on the Company’s securities, and to correct any material mistake or misinformation in the market. Alt Resources discharges these obligations by releasing information to the ASX in the form of an ASX release or disclosure in other relevant documents.
The following procedures will apply to safeguard against breaches of Alt Resource’s continuous disclosure obligations:
a) directors and senior management must immediately notify the CEO and/or the Company Secretary as soon as they become aware of information that should be considered for release to the market;
b) the CEO and/or the Company Secretary will:
(i) review the material information reported;
(ii) determine, in consultation with all necessary parties as appropriate, whether any of the material information is required to be disclosed to the ASX; and
(iii) co-ordinate the actual form of disclosure with the relevant members of management.
c) where a decision is made that the item or information does not warrant an ASX release, the CEO/Company Secretary is to advise directors of the rationale for the decision.
Persons to whom this policy applies
This policy applies to:
- all directors of Alt Resources;
- all members of senior management; and
- all employees.
Release of information to others
The Company must not release material price sensitive information to any person if that information is required to be disclosed to the ASX, until cleared by the ASX. The CEO and/or the Company Secretary or a nominee of the CEO/Company Secretary will advise all relevant parties when the ASX release has been announced by the ASX. All the information disclosed through the ASX is to be promptly placed on the Company’s investor web site after clearance by the ASX.
For all information/presentations/briefings etc. which are to be provided to third parties, each individual is responsible for ensuring that a copy of the material is provided to the CEO and/or the Company Secretary prior to presenting that information externally.
All inquiries from third parties must be referred to the CEO and/or the Company Secretary. All material presented at an analyst briefing, bank or other third party must be approved by or referred through the CEO and/or the Company Secretary prior to the briefing.
All inquiries from the media must be referred to the CEO and/or the Company Secretary.
Management of the Policy
The Company Secretary is responsible for:
- liaising with the ASX in relation to continuous disclosure matters;
- ensuring timely disclosure of material information to the ASX;
- liaising with the Executive Chairman, Managing Director and others in relation to the form of disclosure by the Company;
- taking reasonable steps to ensure that management of the Company are aware of the Company’s disclosure obligations and their obligations under this policy;
- keeping records of releases to the ASX and any material correspondence with ASX; and
- reviewing this policy in light of any changes to the rules governing continuous disclosure, changes in Company operations and structure and, where appropriate, recommending changes to the Board for its approval.