Continuous Disclosure Policy
Healthscope Notes Limited (“Healthscope”) is committed to the provision of timely, full and accurate disclosure to the market.
This Policy aims to ensure compliance with the continuous disclosure obligations under the Corporations Act and the Australian Securities Exchange (“ASX”) Listing Rules, such that:
- All investors have equal and timely access to material information concerning Healthscope – including its financial situation, performance, ownership and governance; and
- Healthscope announcements are factual, complete and presented in a clear and balanced way.
Disclosure of material information
Healthscope will immediately notify the ASX of any material information concerning Healthscope in accordance with regulatory requirements.
“Material information” in this Policy means any information concerning Healthscope, which a reasonable person would expect to have material effect on the price or value of any listed securities issued by Healthscope. A reasonable person would be taken to expect information to have a material effect on the price of Healthscope listed securities if that information would, or would be likely to, influence investors in deciding whether to buy, hold or sell Healthscope listed securities.
Exceptions
In accordance with ASX Listing Rule 3.1, Healthscope is not required to disclose material information if:
- A reasonable person would not expect the information to be disclosed; and
- The information is confidential (and the ASX has not formed the view that the information has ceased to be confidential); and
- The information is of a kind which is exempted by Listing Rule 3.1 (being where the information is insufficiently definite to warrant disclosure, concerns an incomplete negotiation or proposal, is generated for internal management purposes, is a trade secret or its disclosure would breach the law).
Responsibilities for disclosure
Healthscope has designated the Executive Chairman and Managing Director of the Healthscope Group and the Finance Director as “Disclosure Officers”.
The Disclosure Officers have responsibility for reviewing proposed disclosures and making decisions in relation to what information can or should be disclosed to the market.
All Healthscope Group staff are required to inform a Disclosure Officer of any potentially material information concerning Healthscope as soon as they become aware of it. If staff are unsure whether information is potentially material, they may discuss the matter with their divisional Chief Operating Officer or a Disclosure Officer.
The Company Secretary is responsible for:
- Overseeing and coordinating disclosure of material information to the ASX;
- Communicating and promoting understanding of this Policy to Healthscope’s Disclosure Officers;
- Providing advice on disclosure of material information, which may include obtaining external legal advice;
- Ensuring all Healthscope releases to the ASX are promptly posted on Healthscope’s website; and
- Reviewing this Policy, at least annually, to ensure continued compliance with the Corporations Act and ASX Listing Rules.
Market Speculation
Healthscope will not generally respond to market speculation and rumours unless required to do so by law or the ASX, for example, in order to prevent a false market in Healthscope’s listed securities. If necessary, Healthscope may request a trading halt in order to prevent trading in Healthscope securities in a false or uninformed market.
External Communication
Other than Healthscope’s Disclosure Officers, no employee can speak on behalf of Healthscope to media, analysts or investors, unless specifically authorised by the Executive Chairman and Managing Director.
Healthscope will not publicly disclose material information before formally disclosing the information to the ASX.
If material information is provided to analysts, the media or other external parties without first being disclosed to ASX, the Company Secretary should be notified of the disclosure immediately, and the Company Secretary will then arrange for disclosure in accordance with this Policy.
Last Reviewed: 15 December 2010