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This report summarises the ASX Continuous Disclosure Listing Requirements Guidance Note 8 in relation to social media monitoring. It provides a quick but complete overview. 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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How To Ensure ASX Listing
Compliance for Social Media
Contact:
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
+61 410 660 107 (Sydney)
or Walter Adamson
+61 403 345 632 (Melbourne)
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