KINSHIP digital Social Media ASX Listing Compliance Guidelines

How To Ensure ASX Listing

Compliance for Social Media

Contact:

walter.adamson@kinshipdigital.com

m: +61 403 345 632 @adamson

www.kinshipdigital.com

“I do agree that social media poses a major risk to

organisations but at this point in time we do not

engage with investors through social media so have

minimal disclosure risk.”

… Company Secretary, ASX-listed company, May 2013.

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Are you a gambler with your

Company’s compliance?

Why you need to listen

Regulatory compliance, and reputation risk:

1. ASX Guidance Note 8: Continuous Disclosure: Listing

Rules 3.1 – 3.1B Effective 1 May 2013

2. Brand & reputation risk

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Brand & reputation risk

Brand risk and reputation damage were rated

by Chief Audit Executives as the highest of

those arising from social media.

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When you need to listen

1. Guidance Note 8 'strongly encourages' an entity that has

not yet disclosed existing market sensitive information to

listen.

2. In the ASX's view, such monitoring should take place

both while the company is awaiting board approval for an

announcement, and where it is relying on any exception

(under Listing Rule 3.1) for confidential information.

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When you need to listen

ASX guidance does not expressly require ongoing monitoring of social

media sites:

• However, it will be necessary for companies to look at their policies

and processes before any market sensitive information arises that

may be affected by the monitoring requirement.

• These policies and processes need to be adequate to ensure that

appropriate persons are aware of the social media sites on which

content about the company may be posted and how those sites will be

effectively monitored for relevant information.

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What you need to listen for

ASX expects companies to monitor social media for:

'any information concerning it that a reasonable person

would expect to have a material effect on the price or value

of the entity's securities‘

Listed entities may also need to ensure that their social

media monitoring is sufficient to detect any rumours that

may be circulating about the entity and affecting the price of

its securities.

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Where you need to listen

A company is expected to monitor:

‘any investor blogs, chat-sites or other social media it is

aware of that regularly include postings about the entity…’

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Other social media sites

1. Reach of social media sites expanding.

2. Rumours circulating on those sites are more likely to be

widely disseminated.

3. Increasingly important for companies to ensure that

social media monitoring is not simply left to marketing

personnel under vague “compliance” instructions.

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How quickly you must react

The general rule is that anything material to the market must

be announced "promptly and without delay“.

At minimum, the ASX must be informed promptly and

without delay, and subsequent discussions will then

resolve when the market needs to be informed.

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How to invest in social media monitoring

Effective social media monitoring and intelligence requires:

1. Access to the right data sources – rule out free tools

2. The right people – focused, trained, data analysts not marketing interns

3. The right training – tools are constantly evolving

4. The most efficient investments – avoiding duplication and staff turnover

5. Effective investments - outsource lower-value activities

6. Coordinated workflow and escalation – don’t drop the ball internally

Most importantly:

You must know how to process DATA into INFORMATION into INSIGHTS

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Listening risks

Risks

Right People

Listening?

Listening Right

Places?

Internal Workflow?

Market Sensitivity?

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Even if a company is already carrying out monitoring of social media for its own purposes the individuals carrying out that work are unlikely to be best placed to quickly identify information that may indicate early disclosure of market sensitive information.

The current social media team may not even be aware of market sensitive information that has not yet been publicly disclosed.

In which case they would not be in a position to identify content that could give rise to a disclosure obligation and accordingly may need to be internally escalated.

Compliance requires coordination

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Board

Management

ASX

Internal Social Media

External Social Media

Compliance Functions

IT

3 Steps to ASX Compliance

• Get started now

• Build expertise in filtering and assessing

• Understand the potential and risksListen Now!

• Cross-company coordination & workflow

• Left hand must know what the right hand is doing

• Internal Audit – Governance, Risk, ControlCoordinate

• Consolidate and rationalise social media expenses

• Right balance of internal and external

• Contracts, KPIs, performanceImprove

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The key to effective social media governance is to identify

which departments provide assurance on risks to the

business and then get them to collaborate with the

Company Secretary or Listing Compliance manager.

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About Kinship Digital

KINSHIP digital is a social consultancy that specialises in understanding,

developing and protecting its clients’ reputation, brands, businesses and

people in Social Media.

Related reading:

Learn How to Manage your Brand and Reputation Risk

Auditing Social Media

Governance Framework for Social Media Audits

6-Step Social Media Audit Plan – for Internal Auditors

How Social Media enables Brand Resilience

Brand Resilience 2 – Social Strategy and Brand Breadth

Top 10 CEO Implications of Social Media

We don’t deliver you social media, we

deliver business outcomes enhanced

by effective social media investments

aligned to your key use cases. This

incorporates social strategy, reporting,

and governance including audit and

assurance.

Learn more by contacting:

Raz Chorev

raz@kinshipdigital.com

+61 410 660 107 (Sydney)

or Walter Adamson

walt@kinshipdigital.com

+61 403 345 632 (Melbourne)

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