Purpose:
This editorial policy establishes guidelines for producing AI-generated articles based on company announcements to the Australian Stock Exchange (ASX), which are subsequently shared online with investors. The policy aims to ensure the accuracy, compliance, and integrity of the content while also promoting transparency, clarity, and timeliness in investor communications.
1. Compliance with ASX Listing Rules
Although content is being shared online rather than directly with the ASX, the following ASX Listing Rules must be adhered to:
- Rule 3.1: Continuous Disclosure – Ensure that material information disclosed through AI-generated articles has already been disclosed to the ASX and is consistent with ASX announcements.
- Rule 3.1B: Material Information – Any information published online that could influence investor decisions or affect the price or value of the company’s securities must be carefully managed to ensure no material omissions or misstatements.
- Rule 3.1C: Disclosure must not mislead the market – Content generated from AI tools must be fully aligned with the company’s official position, and care must be taken to avoid misleading interpretations of information.
- Rule 3.1D: Timeliness – AI-generated articles should be distributed promptly after ASX announcements are made to ensure market participants have timely access to the information.
2. Pre-Publication Review and Approval
Before any AI-generated content is shared with investors:
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Manual Review Process: All AI-generated content must undergo review by qualified company personnel (such as the legal, compliance, and communications teams) to ensure that it is in full compliance with ASX Listing Rules, company policies, and relevant legal requirements.
- Verification: The content must be checked for accuracy against the original ASX announcement.
- Approval by Senior Management: Content should be approved by the company's CEO, CFO, IR account managers or other authorized senior executives before it is distributed.
- Options exist for Senior Management to edit, reject or publish the content: All content is emailed for approval to publish. AI-generated content must always be subject to final sign-off by a responsible individual, ensuring that it accurately reflects the company’s disclosures and does not misrepresent or omit any material facts.
3. Accuracy and Completeness
AI-generated content must:
- Be Factually Accurate: All data, financials, company updates, and any other material details must be double-checked and verified. AI-generated content must not introduce errors or distortions of any kind.
- Reflect the Original ASX Announcement: The AI tool should only generate summaries or expansions based on publicly available ASX announcements that have already been disclosed to the market. It must not introduce new, unannounced, or speculative information.
- Be Balanced: Any financial results, forward-looking statements, or projections should be presented in a way that is consistent with the company’s official stance and the full ASX announcement.
4. Transparency
- Clear Labelling of AI Content: AI-generated articles must clearly disclose that the content has been created using AI, particularly if it is a summary, reformatting, or interpretation of the company’s ASX announcements. This helps maintain transparency and build trust with investors.
- Example: "This article was generated with the assistance of AI, based on information previously disclosed in the company’s ASX announcement"
- Disclaimer for AI Content: Where appropriate, include a disclaimer stating that the content is based on AI-driven analysis and has been reviewed for accuracy, but readers should rely on the official ASX announcements for the most authoritative and complete information.
5. Market Sensitivity and Materiality
- Timely Distribution: AI-generated content should be made available to investors only after the relevant ASX announcement has been issued to avoid the potential for selective disclosure.
- Material Information: Only material information that has already been disclosed to the ASX should be included in AI-generated articles. It is critical that online content does not disclose material non-public information that could affect the company's stock price or investor decision-making.
6. Forward-Looking Statements
- Proper Disclaimers: If forward-looking statements are included in the AI-generated content (for example, projections of future earnings or business outcomes), these must include appropriate cautionary language, as per ASX requirements.
- Example: "This content includes forward-looking statements based on current assumptions and expectations. Actual results may differ due to various factors, including market conditions, business performance, and other risks."
- Alignment with Official Guidance: AI-generated content must align with any guidance or projections officially released by the company. Overly optimistic or speculative language should be avoided.
7. Ethical and Legal Considerations
- Avoiding Misleading Content: AI-generated content must not intentionally or unintentionally mislead investors. This includes presenting a distorted view of the company's financial health, future prospects, or any material event.
- Confidentiality: Ensure that AI-generated content does not include any confidential or insider information that has not been publicly disclosed via the ASX. This includes any details that could be considered "inside information" under Australian securities law.
- Fair Disclosure: All information published online must be consistent with the principle of fair disclosure, ensuring that no investor has access to selective or preferential content.
8. Tone and Language
- Professional and Neutral: AI-generated content must use a professional, clear, and neutral tone, avoiding any language that could be perceived as promotional, biased, or speculative.
- Investor-Friendly: While the tone should remain neutral and objective, the content should still be accessible and understandable to investors, avoiding overly technical jargon where possible.
9. Audit Trail and Record-Keeping
- Documentation: Detailed records must be maintained for each AI-generated article, including the original ASX announcement, the AI-generated content, review and approval notes, and the final version published. This documentation will support future audits and ensure accountability.
- Content Versioning: Track all versions of the content produced by the AI tool, noting any changes made during the review process.
10. Ongoing AI Model Monitoring and Updates
- AI Model Transparency: The AI system used for content generation should be periodically reviewed and updated to ensure that it produces accurate, unbiased, and reliable content.
- Training and Improvements: The AI should be trained on the latest financial data, ASX announcements, and investor communication trends to produce high-quality content that aligns with industry standards and regulatory requirements.
Conclusion:
This editorial policy ensures that AI-generated content derived from ASX announcements and shared with investors online is accurate, timely, transparent, and compliant with all relevant ASX Listing Rules and legal requirements. By maintaining rigorous standards of oversight, compliance, and accountability, the company can effectively use AI to enhance its investor communications while safeguarding the integrity of its public disclosures.
This policy helps ensure that AI tools are used responsibly and transparently, while protecting the company’s legal and regulatory obligations regarding investor communications and market disclosure.