ASX & Shareholder Disclosure

Disclosure ASX and Shareholder Communication

The Board has delegated the responsibility to Management of on-going disclosure to the Australian Securities Exchange Ltd, of any material issue that may be considered relevant that shareholders should be made aware of to assist them in their assessment of Wide Bay’s operations and to form an independent opinion.

In addition the Board is totally committed to keeping shareholders fully informed, where necessary, by direct communication, public communication and posting of these communications on Wide Bay’s website. The Chairman specifically encourages discussion from interested parties at general meetings at which the Auditor is requested to attend and is available to answer any shareholders questions in relation to the audit and his report.

Provision of Information

The principle areas of communication to shareholders include:-

• disclosures to the ASX;
• through the website; and
• press releases where necessary directly to shareholders.

The content of the continuous disclosure will particularly include information “that a reasonable person would expect to have a material effect on the price or value of Wide Bay Australia Ltd (Wide Bay) securities and or would be likely to influence persons who commonly invest in securities in deciding whether to acquire or dispose of Wide Bay’s securities”

Company Website

The Company website provides:-

• specific announcements to the market and media releases;
• copies of press releases;
• announcements;
• annual and half-yearly reports;
• Wide Bay's Board Charter; and
• Corporate Governance policies and procedures.

General Information

Notices of meetings are called in accordance with Wide Bay’s Constitution and the Corporations Act 2001 and include details of the meeting and related explanatory information in respect of the business of the meeting.

Wide Bay will at all times endeavour to provide information to all shareholders, however, acknowledges from time to time there may be specific questions or queries from individuals exercising their rights as shareholders. The Board and Managing Director are available to assist in providing relevant information.

Shares & Securities Trading Policy
For Directors, Key Management & Staff

The Board is conscious of the legal prohibition on insider trading and all Directors, officers and employees are prohibited from trading in Wide Bay Australia Ltd (“Wide Bay”) shares or other securities while in possession of price sensitive information.  This information is classified as information that a reasonable person would expect to have a material effect on the price or value of securities.  The requirement also applies to entities or trusts that are controlled by any of the Directors, officers or employees. 

The responsibility for compliance is the personal responsibility of every party involved and any failure to comply will be considered by the Board as a serious breach.

In accordance with the ASX Listing Rules, particularly Rule 12.12, Wide Bay’s policy addresses specific circumstances in accordance with Rule 12.12.1. 

Wide Bay’s closed periods, which applies to Directors and designated employees are:-

• trading in Wide Bay’s listed products on the ASX, currently fixed shares, is restricted to a four week period immediately following:-
  • the announcement to the ASX of Wide Bay’s 6 months trading results;
  • the announcement to the ASX of Wide Bay’s 12 months trading results;
  • the annual general meeting,
  • any profit forecasts issued by the Board in respect of the current year’s trading.

These trading periods however are still subject to limitations on trading during these periods, if the Director or designated employee is in possession of price sensitive information not available to the market. 

Approval to trade in these periods:-

• in the case of Directors requires approval from the Chairman,          
  
• in the case of designated employees, who are not Directors, approval must be obtained from the Managing Director or his nominee,
  
• in the case of the Chairman, approval must be obtained from the Chairman of the Audit Committee.

It is possible for trading outside of these periods, but only if special and extenuating circumstances exist.  These special circumstances would in general be limited to personal circumstances creating hardships or other internally related circumstances.  In the case of designated employees, permission must be obtained from the Managing Director or in the case of Directors, from the Chairman and in the case of the Chairman, from the Chairman of the Audit Committee.

The Company Secretary will retain a register of designated employees and their relevant trading activities. 

This policy encompasses all employees of Wide Bay if they are in possession of price sensitive information not available to the market and such that a reasonable person would expect to have a material effect on the price or value of the securities. 

Employee Distribution

This policy will be issued to all existing employees of Wide Bay and will form part of the procedure applicable to the employment of all new staff as part of their induction package. 

This policy is subject to constant review by the Board as considered necessary and appropriate to comply with the relevant legislation applicable.