Broadly speaking, materiality is defined under the ASX Listing Rules by reference to something of value 9ie: asset wise, revenue wise, profit wise, or contract value wise). Rarely is the concept of materiality applied to such things as customer spread, numbers, ARPUs, etc.
That said, once a company changes its emphasis such that it begins reporting on such matters (as if they were materially relevant), then both the character and the quality of the materiality undergoes some change. On this, both the ASX and ASIC are still coming to grips.
The reality, by their own conduct, SWT have converted the concept of reporting customer numbers (along with those of PTL) as if they were material. In this instance, with materiality being determined by reference to whether or not the information provided is designed to inform and /or influence the behaviour of shareholders.
So whilst the jury may still be out on whether the concept of materiality has been adversely impacted here (ie: misused, etc), clearly: 1) the reporting of price sensitive or otherwise price sensitive intended information may well have been breached from a Listing Rules perspective; and 2) the accuracy of the reported information may well have been misleading in either the way it has been reported, presented, or referenced (in which case, another prospective breach of the Listing Rules).
Materiality (in a factual value sense) and continuous disclosure are, but 2 of the ways in which companies need to adhere (ie: comply) from a Listing Rules perspective. Providing clear, accurate and correct (ie: not misleading) information represent other ways that proper compliance and governance is maintained.
ASIC, therefore, should be interested, but perhaps did not stray all that far outside the square.
