KINSHIP digital Social Media ASX Listing Compliance Guidelines


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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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KINSHIP digital Social Media ASX Listing Compliance Guidelines

  1. 1. How To Ensure ASX ListingCompliance for Social MediaContact:walter.adamson@kinshipdigital.comm: +61 403 345 632
  2. 2. “I do agree that social media poses a major risk toorganisations but at this point in time we do notengage with investors through social media so haveminimal disclosure risk.”… Company Secretary, ASX-listed company, May 2013.2Are you a gambler with yourCompany’s compliance?
  3. 3. Why you need to listenRegulatory compliance, and reputation risk:1. ASX Guidance Note 8: Continuous Disclosure: ListingRules 3.1 – 3.1B Effective 1 May 20132. Brand & reputation risk3
  4. 4. Brand & reputation riskBrand risk and reputation damage were ratedby Chief Audit Executives as the highest ofthose arising from social media.4
  5. 5. When you need to listen1. Guidance Note 8 strongly encourages an entity that hasnot yet disclosed existing market sensitive information tolisten.2. In the ASXs view, such monitoring should take placeboth while the company is awaiting board approval for anannouncement, and where it is relying on any exception(under Listing Rule 3.1) for confidential information.5
  6. 6. When you need to listenASX guidance does not expressly require ongoing monitoring of socialmedia sites:• However, it will be necessary for companies to look at their policiesand processes before any market sensitive information arises thatmay be affected by the monitoring requirement.• These policies and processes need to be adequate to ensure thatappropriate persons are aware of the social media sites on whichcontent about the company may be posted and how those sites will beeffectively monitored for relevant information.6
  7. 7. What you need to listen forASX expects companies to monitor social media for:any information concerning it that a reasonable personwould expect to have a material effect on the price or valueof the entitys securities‘Listed entities may also need to ensure that their socialmedia monitoring is sufficient to detect any rumours thatmay be circulating about the entity and affecting the price ofits securities.7
  8. 8. Where you need to listenA company is expected to monitor:‘any investor blogs, chat-sites or other social media it isaware of that regularly include postings about the entity…’8
  9. 9. Other social media sites1. Reach of social media sites expanding.2. Rumours circulating on those sites are more likely to bewidely disseminated.3. Increasingly important for companies to ensure thatsocial media monitoring is not simply left to marketingpersonnel under vague “compliance” instructions.9
  10. 10. How quickly you must reactThe general rule is that anything material to the market mustbe announced "promptly and without delay“.At minimum, the ASX must be informed promptly andwithout delay, and subsequent discussions will thenresolve when the market needs to be informed.10
  11. 11. How to invest in social media monitoringEffective social media monitoring and intelligence requires:1. Access to the right data sources – rule out free tools2. The right people – focused, trained, data analysts not marketing interns3. The right training – tools are constantly evolving4. The most efficient investments – avoiding duplication and staff turnover5. Effective investments - outsource lower-value activities6. Coordinated workflow and escalation – don’t drop the ball internallyMost importantly: You must know how to process DATA into INFORMATION into INSIGHTS11
  12. 12. Listening risksRisksRightPeopleListening?ListeningRightPlaces?InternalWorkflow?MarketSensitivity?12Even if a company is already carrying outmonitoring of social media for its ownpurposes the individuals carrying out thatwork are unlikely to be best placed to quicklyidentify information that may indicate earlydisclosure of market sensitive information.The current social media team may not evenbe aware of market sensitive information thathas not yet been publicly disclosed.In which case they would not be in a positionto identify content that could give rise to adisclosure obligation and accordingly mayneed to be internally escalated.
  13. 13. Compliance requires coordination13BoardManagementASXInternal SocialMediaExternal SocialMediaComplianceFunctionsIT
  14. 14. 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, performanceImprove14
  15. 15. The key to effective social media governance is to identifywhich departments provide assurance on risks to thebusiness and then get them to collaborate with theCompany Secretary or Listing Compliance manager.15
  16. 16. 16About Kinship Digital
  17. 17. KINSHIP digital is a social consultancy that specialises in understanding,developing and protecting its clients’ reputation, brands, businesses andpeople in Social Media.Related reading:Learn How to Manage your Brand and Reputation RiskAuditing Social MediaGovernance Framework for Social Media Audits6-Step Social Media Audit Plan – for Internal AuditorsHow Social Media enables Brand ResilienceBrand Resilience 2 – Social Strategy and Brand BreadthTop 10 CEO Implications of Social MediaWe don’t deliver you social media, wedeliver business outcomes enhancedby effective social media investmentsaligned to your key use cases. Thisincorporates social strategy, reporting,and governance including audit andassurance.Learn more by contacting:Raz 410 660 107 (Sydney)or Walter 403 345 632 (Melbourne)17