Tom Pockett
National President
16 September 2002
Mr Paul Phenix
Senior Accounting Adviser
Australian Stock Exchange
530 Collins Street
Melbourne 3000
Dear Mr Phenix
Proposed ASX Listing Rule Amendments
Enhanced Disclosure (Section 4)
The Group of 100 (G100) is pleased to provide comments on the proposals to improve periodic disclosure.
The G100 strongly supports the proposals not to prescribe a standard form for the half-yearly reporting announcement and believes that it will assist companies in streamlining the process of communication with the market. In the absence of a prescribed format under which information often needed to be 'fitted' into an appropriate heading or item, the proposed approach will enable companies to present information in a format which best suits the nature of their activities and reflects industry characteristics and circumstances.
The G100 also believes that a similar approach should be adopted in respect of preliminary final reports. We do not, at this stage, support the second alternative in respect of preliminary final reports as it is not seen to be practicable to require a 'true results preliminary announcement' prior to audit clearance having occurred. However, this approach could be provided as an option for those companies where audit clearance occurs before the announcement date. Where such an approach is adopted we believe that the narrative discussion and explanation should deal with the types of issues raised in the G100 Guide as set out in Guidance Note 10.
The G100 supports the reduction in the lodgement time to sixty days after the end of the reporting period. While we do not believe a change of this nature would impose significant burdens for the majority of our members, it may do so for smaller listed companies. In this regard there may be a case for having a different lodgement requirement for the smaller listed companies, say, those not ranked in the Top 300 by market capitalisation.
Yours sincerely
Tom Pockett
National President
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