Crowe Horwath Australia is a listed company on the Australian Stock Exchange (ASX). Part of the regulatory listing requirements of the ASX is ASX Guidance Note 8 (GN8). It requires companies to monitor any “potential market-sensitive information” which may appear in social media. Companies must practise social media monitoring of their company and directors, in order to identify market-sensitive information that could influence their share price. Crowe Horwath contracted KINSHIP digital to perform this service.
Three significant points must be addressed and assessed by buyers of social media monitoring for ASX compliance purposes, in accordance with GN8:
- ASX GN8 is about compliance, governance, risk and control
- GN8 due diligence requires an exception reporting methodology
- GN8 exception reporting is skilled and labour intensive.
Due to these points, ASX GN8 multi-stage screening process cannot be highly automated. And, once built, execution of the methodology must be cost-effectively executed. Most social media monitoring firms serving marketing needs lack the procedure-oriented capabilities to build and apply such an exception methodology to social media data, let alone at an acceptable price point.
KINSHIP digital provided the Company Secretary with specific details of unique items; these had to be the original items appearing in social media and not duplicates, repeats or simply commentary on previously public information. In particular, they could not be duplicates, repeats or commentary on items from the online traditional media.
This “by exception” reporting is very important. Company Secretaries already receive social media and online reports from third-party monitoring services. KINSHIP digital looked for those things which these other parties were likely to have missed, while at the same time not duplicating what the Company Secretary had already received.
The outcome is a cost-effectively delivered, effective and efficient multi-stage screening methodology for exception reporting of market sensitive information.
Note: Crowe Horwath Australia Ltd was delisted from the ASX on 7 Jan 2015 as a result of being acquired by Findex Australia.