Here are the key points from the announcement by Biotron...

Here are the key points from the announcement by Biotron Limited:

1. Continuous Disclosure Policy Revision:

   • Biotron Limited has updated its Continuous Disclosure Policy, as requested by the ASX (Australian Securities Exchange).
   • The revised policy is now available on the company’s website under corporate governance.

2. ASX's Concerns:

   • ASX highlighted issues with Biotron’s previous policy:
     • The company did not disclose a $500,000 loan facility promptly.
     • Biotron’s response to an ASX query lacked sufficient understanding of market-sensitive information and ASX disclosure obligations.

3. Policy Enhancements:

   • Chairman’s Role: The Chairman is now an additional officer responsible for compliance with disclosure obligations.
   • Board Approval: All disclosures under Listing Rule 3.1 now require full board review and approval.
   • Decision-Making Chart: A decision-making tool is introduced to assist in determining necessary disclosures.
   • Glossary of Terms: Clarification of key terms like 'material effect,' 'immediately,' and 'aware' under Listing Rule 3.1.

4. Director and Employee Training:

   • All directors and senior employees received the updated policy and a reminder about their disclosure obligations.

5. Disclosure Process:

   • The Chairman, Managing Director, and Company Secretary jointly decide if information is material enough for disclosure.
   • If disclosure is warranted, the Company Secretary drafts the announcement, which undergoes review and board approval before release.

6. Key Disclosure Examples:

   • Certain events require immediate disclosure if they impact share value, including:
     • Major transactions, acquisitions, or disposals.
     • Material legal proceedings.
     • Changes in financial performance expectations.
     • Notices regarding takeovers.

7. Exceptions to Disclosure:

   • Disclosure is not required if:
     • It breaches the law, pertains to incomplete negotiations, is speculative, intended for internal management, or involves trade secrets.
     • The information remains confidential, and disclosure is not expected by a reasonable person.

8. Legal Clarifications:

   • The Corporations Act clarifies the 'material effect' on share price and defines 'immediately' as acting promptly without undue delay.
   • Biotron can be penalized for intentionally withholding market-sensitive information.