An officer of a listed entity who is faced with a decision on whether information needs to be disclosed under Listing Rule 3.1 may find it helpful to ask two questions:
(1) “Would this information influence my decision to buy or sell securities in the entity at their current market price?”
(2) “Would I feel exposed to an action for insider trading if I were to buy or sell securities in the entity at their current market price, knowing this information had not been disclosed to the market?”
If the answer to either question is “yes”, then that should be taken to be a cautionary indication that the information may well be market sensitive and, if it does not fall within the carve-outs to immediate disclosure in Listing Rule 3.1A (see below), may need to be disclosed to ASX under Listing Rule 3.1.
https://www.asx.com.au/documents/about/abridged-continuous-disclosure-guide-clean-copy.pdf
An officer of a listed entity who is faced with a decision on...
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