Policy · Capital Markets & Securities — ECM/DCM and Disclosure

Continuous disclosure policy and disclosure committee charter

Board-approved continuous disclosure policy for an ASX-listed entity, with a disclosure committee charter and a disclosure decision record. It covers LR 3.1 to 3.1B, ss 674 and 674A, leaks, analyst briefings and use of AI tools.

Kind
Policy. A policy or procedure for a firm or client.
Where it applies
Australia, New Zealand, United Kingdom (England and Wales)
AI use
Yellow AI can help in set ways. A lawyer checks specific points before use.
Law stated as at
17 October 2026
Status
Maintained. Checked on 17 October 2026 against the 7 authorities it cites, for Australia, New Zealand and United Kingdom (England and Wales).
Version
1
Source
Written for this library

When to use it

Use when a listed entity adopts or refreshes its continuous disclosure policy, or prepares to list. Adapt for entities listed on other markets. Not a substitute for advice on whether particular information must be disclosed.

How AI may be used

AI may help monitor media and draft flags or announcement wording from a lawyer’s facts brief. Materiality and disclosure decisions are made and approved by people.

AI may

  • Monitor news, social media and trading data and flag items for the Disclosure Officer
  • Assemble a who-knew-what-when chronology from documents for the disclosure decision record
  • Check a draft announcement for consistency with earlier announcements and guidance

AI must not

  • Must not decide whether information is material or whether the LR 3.1A carve-out applies
  • Must not originate statements about future matters such as forecasts or guidance
  • Must not process unannounced price-sensitive information in a tool outside the entity’s approved environment

The lawyer checks

  • Policy reflects current Listing Rules, Guidance Note 8 and the entity’s actual decision-makers
  • Escalation routes work outside business hours and during leaks
  • AI-use section matches the entity’s approved tools and information barriers

Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.

Authorities

Official form

Open the official form. Always use the current version from the issuer.

Read the full text

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