SP1 (ASX) Ann: Amendments to Continuous Disclosure Policy

Originally posted by quiet_observer: ↑

no, imo you're wrong
the actual recommendation from the independent expert below specifically talks about all strategically important contracts irrespective of revenue, but isx ignoring this recommendation and saying it will only release strategically important contracts including those that are material (even if not material revenue) at a later time

"ISX amend its policy and approach to disclosure of material contracts such that, where a contract is identified as being strategically important (such that disclosure is required under ASX Listing Rule 3.1), ISX immediately release an announcement following execution of the contract (rather than at the point of integration or where ISX begins to earn revenue under the contract, which is its current practice). We further recommend that the announcement of entry into a strategically significant contract should clearly disclose any conditions, uncertainty or other contingencies in respect of the contract that must be satisfied or resolved before revenue can be generated under the contract;"

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Hi @quiet_observer, the key words from the independent expert here are "where a contract is identified as being strategically important". In the paragraph before this one, it is also said ISX needs to seek further advice on "(i) identifying when a contract or matter may be sufficiently material so as to require disclosure for the purposes of ASX Listing Rule 3.1;

ISX has said "Upon ISX determining that a contract is material to its earnings, an announcement shall be immediately released to the MAP which will clearly articulate the significance and term of the contract." but that ISX will not announce one that that is strategically important or material for some other reason (other than revenue) but ISX will release it when ISX has a security deposit and integration has initiated.

I would agree that ISX has not changed its policy strictly with the recommendations, but the difference does appear to be trivial and reasonable. I am assuming that the independent consultant report has included advice and that it is not totally mandatory that ISX follow the advice to the letter.

The independent expert also noted that ISX does not have any contracts that fit that description.