Proposed ASX Listing Rule Amendments - Enhanced Disclosure (Sections 2 & 3)

16 September 2002

Ms Catherine Officer
Legal Counsel & Manager - Issuers and Quoted Products
Australian Stock Exchange
530 Collins Street
Melbourne 3000

Dear Ms Officer

Proposed ASX Listing Rule Amendments
Enhanced Disclosure (Sections 2 & 3)

The Group of 100 (G100) is pleased to comment on proposals to amend the listing rules.

Section 2 - Continuous Disclosure
The G100 is concerned that the adoption of the proposals in respect of rumour and speculation may unnecessarily burden a company to respond, with the response itself leading to demands for the provision of further or more complete information. For example, a response to speculation that a special dividend is expected may require a company to disclose additional information above and beyond what it would have otherwise been required to disclose, including information about financial performance, financial position and operating activities, to properly deal with any rumour/speculation.

While the G100 is not opposed to the publication of correspondence with companies as is the current ASX practice we are concerned that the tendency to 'trial by media' be avoided.

Section 3 - Electronic Lodgement
The G100 supports the mandating of electronic lodgement provided that the ASX has appropriate systems and processes in place to facilitate efficient and reliable lodgement. However, while unlikely to be a factor for G100 members mandating a specific form of lodgement effective from 1 July 2003 may impose burdens for smaller listed companies. In this event it may be reasonable to have a longer transition period for these companies.

Yours sincerely

Tom Pockett
National President