Disclosure Policy

The Talent2 disclosure policy is premised on core values of innovation, honesty, integrity and respect for others.

Objectives

The Talent2 market disclosure policy aims to ensure:

• full and timely disclosure of Talent2’s activities to shareholders and the market
• equal opportunity for all stakeholders to receive and obtain externally available information issued by Talent2
• compliance with all applicable laws and regulations
• disclosure in accordance with “best practice”

Information to be disclosed

• Talent2 will immediately disclose to the market any price sensitive information.
• Information is “price sensitive” if a reasonable person would expect that the information would have a material effect on the price or value of Talent2’s securities.
• Information is considered to have a material effect on the price of Talent2’s securities if that information would, or would be likely to, influence investors in their decision to buy hold or sell Talent2 securities.

Exceptions

In accordance with Australian Stock Exchange (ASX) Listing Rule 3.1, Talent2 may, if it is in the best interests of the company, elect not to disclose price sensitive information if:

• a reasonable person would not expect the information to be disclosed; and
• the information is confidential; and
• the information is of a kind exempted by ASX Listing Rule 3.1

Information is exempt from disclosure by ASX Listing Rule 3.1 if:

• disclosure would breach the law
• is part of an incomplete proposal or negotiation
• comprises matters of supposition or is indefinite
• is generated for internal management purposes; or
• is a trade secret

Authorities

The following directors and officers of Talent2 are disclosure officers authorised to make pubic disclosure of information:

• Chairman
• Managing Director
• Chief Executive Officers
• Chief Financial Officer
• Company Secretary 

Other employees and directors may only disclose material or commercially sensitive information about Talent2 to external parties with prior written authorisation from the Chairman or Managing Director.

Roles and responsibilities

Disclosure officers

Disclosure officers are responsible for the review of proposed disclosures and for decisions regarding what information can and should be disclosed to the market.

Other directors and executives

All other directors and executives are required to inform a disclosure officer of any potentially “price sensitive” information concerning Talent2 as soon as they become aware of it.

Employees

Talent2 employees are required to inform a disclosure officer of any potentially “price sensitive” information concerning Talent2 as soon as they become aware of it.

Promoting compliance

Employees are encouraged and requested to carefully consider whether information in their possession might be “price sensitive” and to seek guidance from the Company Secretary if they are in doubt.

Market speculation

• It is Talent2 policy not to comment upon market rumours or speculation.
• Talent2 reserves the right to make comment if information is factually incorrect or misinterpreted and it is in the best interests of shareholders to make comment.
• Talent2 will comment on market rumours if asked to do so by the ASX because there could be a false market in Talent2 securities.

External communications

Response to queries

• Talent2 will treat all legitimate requests for information equally and respond in a timely manner.
• Talent2 will not disclose price sensitive information to any investor or analyst before formally disclosing the information to the market.

Analyst briefings

• Generally, no briefings will be made in the two months prior to the scheduled release date of half yearly and annual results.
• If possible, at least two Talent2 representatives will be present at any analyst briefings.
• All presentation material used in analyst briefings will be lodged with the ASX prior to commencement of the briefing and posted on the Talent2 website.
• If material of a price sensitive nature is inadvertently disclosed at any briefing, that information will be formally disclosed to the ASX immediately after the briefing and posted on the Talent2 website.

Media contact

• Employees may respond to queries from the media only with the prior authorisation of the Managing Director or a Chief Executive Officer.
• All media queries should be immediately referred to a disclosure officer.

Trading halts

Talent2 may request a trading halt from the ASX to prevent its securities being traded in an ineffective and uninformed market.