The aim of this policy is to:
- Ensure that Evolution Mining’s employees, contractors and service providers are clear on the content restrictions and approval process required prior to the release to an external party or parties of any Evolution branded communication or communication which may be attributed to Evolution
- Ensure that all external messaging and communication complies with Evolution’s Confidentiality, Continuous Disclosure and Securities Trading policies and with the stringent reporting and continuous disclosure requirements in relation to material information Evolution is bound by as a listed company on the Australian Securities Exchange (ASX). Penalties in relation to breaches of these ASX requirements are significant
- Minimise the risk of a regulatory breach, adverse publicity, damage to Evolution’s reputation or damage to stakeholder relationships by ensuring all external messaging and communication is in line with Evolution’s Values, Policies and Principles, and reflects the agreed position taken by Evolution on the subject matter being communicated
- Establish the protocol for handling media enquiries and for providing Evolution related information to external parties
2.1 This policy applies to:
- a) All Evolution employees, contractors and service providers (“you”)
- b) Any written or verbal communication to an external audience on behalf of or in relation to Evolution, including but not limited to: shareholders, investors, any form of media, analysts, industry representatives, Government representatives, statutory and regulatory bodies, community stakeholders, unions, industrial tribunals or external participants at networking events or workshops
- c) All forms of formal and informal Evolution branded communications intended for an external audience or that has a reasonable chance of ending up in the public domain, including but not limited to: Evolution publications, advertisements, advertorials, newsletters, videos, reports, submissions to Government or regulatory bodies, general communications, emails, speeches or presentations
2.2 Evolution has a separate Social Media Policy which sets out your obligations in relation to the use of social media. The Social Media Policy applies in conjunction with this policy.
Evolution Spokesperson: The Executive Chairman, the Chief Financial Officer, the General Manager Investor Relations and the Company Secretary (together, Spokespeople).
External Communication: All communications intended for an external party, or that have a reasonable chance of ending up with an external party, as detailed in Clauses 2.1(b) and 2.1(c) of this policy.
Material Information: Information is material if that information would, or would be likely to, influence persons who commonly invest in securities in deciding whether to acquire or dispose of Evolution’s securities. Material Information has the same meaning as the information for which the continuous disclosure obligations under the ASX Listing Rules applies.
Nominated Approver: Identified roles for which the incumbent is authorised to approve specific content in External Communications that falls within their subject matter expertise, as detailed in Clause 4.2.2 of the External Communication Procedure.
Approval Process for External Communications
4.1 Unless you are a Nominated Approver, you must not release, publish, submit or present an External Communication to any external party or express views, opinions or policy which may be attributed to Evolution unless you have received written approval to do so from an Evolution Spokesperson.
4.2 The Evolution Spokespeople and/or Nominated Approvers may, from time to time, designate others to release, publish, submit, present and/or approve content in an External Communication and on such occasions must provide prior written approval of such designated authority.
Approval Process Exceptions
4.3 The Approval Process does not apply to general email correspondence, however any emails from an Evolution email address to an external party must be written as if they were going to end up in the public domain and must be in line with Evolution’s Values, Policies and Principles, and reflect the agreed position taken by Evolution on the subject matter being communicated.
4.4 The Approval Process does not apply to “prescribed events” such as incidents or events nominated under State based legislation which must be notified to appropriate regulator(s) without delay; in such cases anyone in the site management structure may make such notification.
4.5 The Approval Process does not apply to general conversations at networking events or workshops, however any comments made on behalf of or in relation to Evolution must be in line with Evolution’s Values, Policies and Principles, and reflect the agreed position taken by Evolution on the subject matter being communicated.
Investor and Media Relations
4.6 All investor enquiries and media enquiries, other than local or regional media, must be directed to the Executive Chairman or a person expressly authorised by the Executive Chairman. In the event that the Executive Chairman is not contactable or is unavailable, an Evolution Spokesperson or the General Manager Investor Relations must be contacted to determine an appropriate course of action.
4.7 All local or regional media enquiries, including local newspapers, local radio, community websites or local television must be directed to the Media Manager or an alternative person expressly authorised by the Executive Chairman. In the event that the Media Manager is not contactable or is unavailable, an Evolution Spokesperson must be contacted to determine an appropriate course of action.
4.8 If you have been expressly authorised to speak to local or regional media, you must not comment on Evolution’s financial or operating results or engage in discussion about Evolution with the investment community and you must immediately inform the Executive Chairman and/or Media Manager of any intended contact with media.
Media and ASX Releases
4.9 All media releases and Australian Securities Exchange (ASX) releases must be approved by the Executive Chairman or a person expressly authorised by the Executive Chairman prior to being lodged or released externally, with reference to, and in compliance with the Continuous Disclosure Policy where applicable. If Evolution’s associates or other third parties are involved or mentioned in a release, they should be made aware of the relevant parts of the release prior to publication.
Analyst Site Visits
4.10 Any materials to be used as presentations, handouts or fact sheets during an analyst site visit must be approved by the General Manager Investor Relations prior to release.
4.11 Site General Managers have the authority to speak to analysts on site visits about site specific matters provided such information is already in the public domain and may, from time to time, designate in writing other Site Managers to speak. The Site General Manager or their designated Manager is not permitted to comment on Evolution’s financial and operating results unless they are given the written authority to do so by an Evolution Spokesperson.
4.12 If you inadvertently disclose any Material Information to an external party, you must immediately notify the General Manager Investor Relations and the Company Secretary, who will proceed with the matter as if it were a notification under the Continuous Disclosure Procedure.
Crisis Communication Plans
4.13 In the event that a site crisis situation arises, Evolution has a Crisis Management Plan which apply at all sites and include a Crisis Communication Plan. The Crisis Communication Plan must be followed in the event of a crisis. If the Executive Chairman is unavailable, the Corporate Crisis Management Team, as defined in the Crisis Response Plan, is authorised to make a holding statement to the media.
4.14 You must not release any information, including photographs or videos, of a site crisis situation unless an Evolution Spokesperson has provided written authorisation for you to do so.
5. EXTERNAL COMMUNICATIONS PROCEDURE
Detailed information about Nominated Approvers and Evolution’s approval process for the release of External Communications is set out in Evolution’s External Communications Procedure. The External Communications Procedure applies in conjunction with this policy.
External Communications Policy
Version Control: 1.0
Review Date: 01/12/2022
Owner: Martin Cummings – General Manager Investor Relations
Approver: Jake Klein – Executive Chairman