Commonwealth Property Office Fund

Principle 5: Make timely and balanced disclosure
Companies should promote timely and balanced disclosure of all material matters concerning the company.

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Continuous disclosure policy and procedures

CMIL has continuous disclosure procedures designed specifically to identify matters requiring disclosure and to allow appropriate announcements to be made in a timely manner consistent with the ASX Listing Rules. These procedures are consistent with those issued by the Bank and are in place to ensure that unitholders and the market are provided with full and timely information about CPA’s activities. They form part of the protocols for managing the use and disclosure of information, and correlate with the policies described in Principle 3.

The Manager has a duty to promptly inform the Board of any matter that can be reasonably expected to have a material impact on the value of the Fund. It operates policies and procedures that are consistent with those of CMIL to facilitate CMIL’s disclosure of material matters. These requirements also form part of the terms of the Management Agreement between CMIL and the Manager.

The release of price-sensitive information is made first through the ASX before release to any other party, and is the responsibility of the Company Secretary.

Upon confirmation by the ASX of the release of information to the market, the announcement is posted to the website of the Fund to ensure accessibility to the widest audience. Presentation of material to analysts, brokers and the media are all subject to these disclosure practices.

The continuous and periodic disclosure requirements are embedded into the Fund’s Compliance Plan, which is subject to ongoing compliance monitoring and forms part of the annual external compliance plan audit.