1. OUR COMMITMENT

NetComm Wireless Code of Conduct and Code of Business Ethics require NetComm Wireless and its employees to act with high standards of honesty, integrity, fairness and equity in all aspects of their employment with NetComm Wireless.

With this in mind, NetComm Wireless commits to dealing fairly, transparently and openly with both current and prospective shareholders, using available channels and technologies to reach widely and communicate promptly. NetComm Wireless commits to facilitating participation in shareholder meetings and dealing promptly with shareholder enquiries.

Our shareholder communications policy is built around compliance with disclosure obligations. Our framework for communicating with shareholders is to concisely and accurately communicate:-

  • our strategy;
  • how we implement that strategy; and
  • the financial results consequent upon our strategy and its implementation.

2. CONTINUOUS DISCLOSURE

The continuous disclosure regime is fundamental to the rights of shareholders to receive information concerning their securities. The most important aspect of NetComm Wireless shareholder communication policy is to comply with the continuous disclosure regime and implement best practice disclosure policy.

Market announcements are posted to NetComm Wireless website immediately after release to the market.

3. INSIDER TRADING

The insider trading rules are an important adjunct to the continuous disclosure regime in ensuring that shareholders are given fair access to material information regarding securities. NetComm Wireless seeks to limit the opportunity for insider trading in its own securities through its continuous disclosure policies and the dealing rules applying to its employees and directors.

4. FINANCIAL REPORTING

Transparent and prompt financial reporting is a key element of listed company disclosure. NetComm Wireless produces half yearly and yearly financial reports and an annual report in accordance with the Corporations Act and listing rules. NetComm Wireless aims to report promptly, comply with all applicable laws, listing rules and accounting standards in its financial reporting and to report in a way which is easy to understand and conveys the materiality of the matters discussed.

NetComm Wireless emails its half yearly and full year results announcements to shareholders who have provided email details to NetComm Wireless.

5. OTHER INFORMATION ABOUT NETCOMM WIRELESS

NetComm Wireless makes non-material announcements about itself from time to time via media releases and other forums and makes available information of interest to shareholders and other stakeholders. These are available on NetComm Wireless website.

6. SHAREHOLDER MEETINGS

Shareholder meetings are an opportunity for shareholders and other guests to hear from and question the board and management of NetComm Wireless. The Chairman and Managing Director make presentations separately before attending to voting on resolutions and general business. The chair of the meeting, usually the Chairman, is responsible for the conduct of the meeting.

NetComm Wireless external Auditor attends its annual general meeting and is available to answer any questions regarding the conduct of and any issues arising from NetComm Wireless audit.

NetComm Wireless conducts annual and extraordinary general meetings in accordance with the Corporations Act, the ASX Listing Rules, ASX Corporate Governance Council guidelines and NetComm Wireless constitution.

NetComm Wireless drafts notices and proxy forms to maximize the ability of readers to understand and vote on the issues presented.

7. CORRESPONDENCE AND REPORTS TO SHAREHOLDERS

NetComm Wireless corresponds periodically with all shareholders to update them on he company’s activities and progress. The correspondence is signed by the Chairman and may, at times, accompany dividend payment advice or cheques.

8. GENERAL INTERACTION WITH SHAREHOLDERS

NetComm Wireless deals with shareholder enquiries promptly and courteously and takes measures to ensure that its agent, Computershare Registry Services, also does so.

9. SHAREHOLDER PRIVACY

NetComm Wireless recognizes that privacy is important and will not disclose registered shareholder details unless required by law. Shareholder details will only be used in accordance with applicable privacy laws.