ASX Compliance Update: Key Reporting and Filing Requirements for Listed Entities

ASX has issued an update outlining critical areas of focus for listed entities in relation to exploration result reporting, annual report compliance, and upcoming periodic filing deadlines. These guidelines aim to promote transparency, accuracy, and timely compliance with ASX Listing Rules.
 
1. Public Reporting of Exploration Results: Emphasis on Balanced Reporting
 
ASX has highlighted two primary considerations for exploration result announcements:

  • Announcement Headers: ASX emphasizes that the headers of exploration results must present a balanced and fair view of the results to avoid misleading investors. Entities should avoid focusing solely on the best grade assay results, especially if they are unrepresentative of the overall data. The JORC Code requires comprehensive reporting, including both high and low grades and/or widths, to provide investors with a full picture of the results.
  • Reporting Metal Equivalents: The use of metal equivalents is increasing, but ASX cautions that such reports can be misleading without appropriate disclosure of key details. Specifically, entities must disclose the grades of all metals involved, the assumed commodity prices used in calculations, and the metallurgical recovery rates. If recovery data is unavailable or estimated with low confidence, the report should not reference metal equivalents.

If ASX considers that an announcement header does not convey a fair and balanced impression of the exploration results being reported or is potentially misleading, or the entity cannot provide a reasonable basis for the metallurgical recovery rates, ASX is likely to reject the announcement or required a retraction or correction. ASX may suspend trading in the entity’s securities until the entity takes appropriate corrective action.

2. Results of Annual Report Spot Checking

In late 2024, ASX conducted a spot check of approximately 100 annual reports to assess compliance with Listing Rules 4.10.1 to 4.10.22. While most entities complied with the requirements, ASX identified errors in the presentation of security holder distribution schedules, particularly in failing to include the percentage of securities held in each category. Entities are encouraged to review their distribution schedules to ensure full compliance.

3. Upcoming Periodic Filing Deadlines

Listed entities should be mindful of the following upcoming deadlines for periodic reports:

  • Preliminary Final Reports (December year-end): Due by Friday, 28 February 2025
  • Statutory Half-Year Financial Reports (June year-end): Due by Friday, 28 February 2025 for most entities, and by Friday, 14 March 2025 for mining exploration and oil/gas entities
  • Annual Reports (December year-end): Due by Wednesday, 30 April 2025 for listed companies and Monday, 31 March 2025 for registered schemes

Failure to submit required documents by the due dates will result in automatic suspension under Listing Rule 17.5.

4. Order of Announcements and Early Release during Reporting Periods

ASX has outlined the required order for the release of financial reports during Appendix 4D, 4E, or 4F reporting periods:

  1. the relevant Appendix and all required documents.
  2. dividend/distribution online form (if applicable).
  3. any additional materials, such as media releases or investor presentations.

Entities can also request early release arrangements for their financial reports by notifying ASX at least 24 hours prior to the intended release.

 If you require any assistance in relation to your reporting requirements, please contact Glenn Vassallo (Managing Director) or Scott Standen (Director).

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Administration

Kryziel Cayabyab

Full bio coming soon!

Associate

Queenie Mei

Queenie is a qualified solicitor with extensive experience in commercial and corporate law, commercial property transactions, and government investment projects. She holds a Juris Doctor degree from Bond University, majoring in Corporate and Commercial Law, and a Bachelor of Commerce in Accounting from Griffith University.

With a strong background in both legal practice and business strategy, Queenie is adept at advising corporate clients, government entities, and international businesses. Throughout her legal career, she has worked at a global top-tier law firm and within the State Government, assisting major Australian and international clients across sectors such as infrastructure, property, and commercial transactions. Her expertise includes negotiating and drafting complex investment agreements (both private and public), addressing corporate governance matters, and managing high-value real estate transactions.

In addition to her legal qualifications, Queenie is an associate member of the Certified Public Accountants and a member of the Chartered Institute of Arbitrators. She is also a professional translator from English to Mandarin and possesses a deep understanding of both Australian and international business and regulatory frameworks.

Queenie is committed to delivering strategic and proactive legal advice, with a particular focus on corporate law, government-funded projects, commercial and property transactions, and legal compliance in prefabricated construction. Her comprehensive skill set and bilingual capabilities make her a valuable asset to clients navigating complex legal and business environments both in Australia and internationally.

Lawyer

Meghan Bower

Meghan is a dedicated and high-performing graduate joining our commercial disputes team with over 5 years of pre-admission experience handling complex personal injury cases. She brings a comprehensive understanding of legal intricacies and a passion for advocating for her clients.

Throughout her career, Meghan has honed her skills in due diligence work, contract review, advice, ADR and multi-jurisdictional litigation including claims in the Supreme Courts of Queensland, New South Wales, Victoria and the Northern Territory. Her journey in the legal field has been marked by her unwavering commitment to client service and her ability to thrive under pressure. Meghan is on the cusp of becoming a qualified lawyer and is eager to contribute her skills and knowledge to GRT’s specialist litigation team.

Associate

Andrew Doak

Andrew begun his legal career as a law clerk in Brisbane in 2008 and continued this through his studies until he graduated with a Bachelor of Laws from Queensland University of Technology in 2011.

He was admitted as a solicitor in 2012 and shortly thereafter moved to London where he worked for global top tier and Magic Circle law firms covering a variety of arbitration and litigation matters. As a highly skilled legal professional, he was responsible for managing multiple teams on document heavy litigation, many of which were centered around energy, commercial, insurance and financial services disputes.

Andrew had worked with senior lawyers and counsel on several high profile and well-publicised cases including class actions, large financial regulatory investigations, and complex international matters before making the decision to return home to Brisbane and join GRT in 2024.

Finance Manager

Chan Hu

Full bio coming soon!

Associate

Dale Copley

Dale began working with GRT Lawyers at the start of 2023 after beginning his legal career with  top-tier firm. He recently retired from professional sports and is relatively new to the legal field, having been admitted in November of 2022.

Dale values the importance of teamwork and advising clients to assist them in achieving their business goals. His experience as a professional athlete has instilled in him the significance of collective efforts and strategic collaboration – qualities that now define his approach to his career in law.

He has a strong interest in equity markets and is acquiring valuable experience by advising on capital raises and various ASX listing rule concerns.

Associate

Rebecca Wei

As an accomplished associate corporate lawyer, Rebecca contributes a fresh perspective and a robust work ethic to our legal team. She has swiftly gained experience in corporate law, demonstrating dedication to assisting clients with their legal needs in an ever-evolving business landscape.

Rebecca specialises in capital market transactional matters, contract drafting, and corporate governance. She has supported senior lawyers in advising a diverse range of clients, including established corporations, startups, and entrepreneurs.

Senior Corporate Advisor

Alana Nisbet

Alana has over 10 years’ experience practicing predominantly in international top tier firms in Australia, London and Guernsey. Her primary practice areas are public and private mergers and acquisitions, equity capital markets and investment funds and she has significant experience advising on complex corporate transactions.

Alana is valued for her exemplary client service and have been ranked as a “Rising Star” for Equity Capital Markets and Mergers & Acquisitions by Legal 500.

Senior Associate

Rachel Hendrie

Rachel is a commercial dispute resolution lawyer who has experience in litigating significant commercial, construction and financial services disputes and in international arbitration. She is experienced with managing document heavy litigation.

Her experience includes assisting major Australian banks in civil penalty proceedings initiated by AUSTRAC in the Federal Court of Australia concerning AML/CTF compliance and fraud investigations, assisting financial services clients with responding to ACCC and ASIC notices including corporate shareholder and contractual disputes for oil and gas clients in Supreme Courts.

Rachel has worked for global top-tier law firms in both Brisbane and Melbourne.

Special Counsel

Alexander Sloan

e alexander.sloan@grtlawyers.com
m +61 406 863 562

PROFESSIONAL SUMMARY

Alex is a commercial litigator with experience in funded litigation and class actions. He has acted for publicly listed companies (both ASX and SGX), large private companies, litigation funders, SMEs, and company directors in a range of commercial disputes.

His experience includes complex, cross-border financial services litigation, class actions, product liability, insolvencies, and corporate disputes.

Alex has prosecuted and defended claims in the Supreme Courts of New South Wales, Victoria, Queensland and the ACT, and in the Federal Court of Australia. He also acted in the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry.

Alex was admitted to practice as a solicitor in 2015 and worked for several years in a national Australian law firm, prior to joining GRT Lawyers in 2021.

 

General Manager

Aylesha James

e aylesha@grtlawyers.com
m 0433 555 812

EXPERTISE

  • Business Operations
  • People and Culture
  • Human Resources
  • Marketing
  • Event Coordination
  • Project Management

PROFESSIONAL SUMMARY

Aylesha serves as the General Manager at GRT Lawyers, providing effective leadership and overseeing the day-to-day operations of the firm. In her role, she manages human resources, marketing, events, and directly supervises the Administration team.

Bringing more than 19 years of experience in office management, senior administration, project and event management, as well as human resources, Aylesha has a proven track record of excellence in high-pressure environments. Her wealth of experience and professionalism ensures the seamless functioning of the firm. Aylesha excels in optimizing operational efficiencies by reviewing and implementing systems, policies, and procedures to support business functions, resulting in impactful results. She adopts a holistic approach, balancing a keen eye for detail with a focus on overarching goals.

Aylesha’s passion lies in people and culture, where she actively fosters strong relationships across all levels of the business. She connects with staff to instill the core values of GRT Lawyers and the GRT Foundation, believing in creating value through people. Her approach involves working with passion and understanding, offering support and cultivating relationships that enhance both business and individual performance.

EXPERIENCE


Her career history encompasses multi-faceted roles giving her exposure to the specialty fields of Human Resources, Marketing and Event Management. Roles have included:

  • Human resources, including recruitment, performance management, staffing, new employee onboarding, employee benefits, payroll and training and development.
  • Marketing – including roles involving the development and implementation of marketing and business development strategies.
  • Background in planning internal and external events from conception through to execution, displaying qualities of a successful event planner: thorough yet precise, expert knowledge, ingenuity in identifying and solving problems and clear, concise communication.

“There’s always another level up. There’s always another ascension. More grace, more light, more generosity, more compassion, more to shed, more to grow.” -Elizabeth Gilbert

Director

Ashley Hill

e ashley.hill@grtlawyers.com
m 0415 150 866

EXPERTISE

  • Commercial litigation
  • International commercial arbitration
  • Energy – oil, gas, coal, and electricity
  • Product liability – recalls and litigation
  • Resources – water and agribusiness
  • Financial services
  • Insurance – including D&O, PI and BI
  • Regulatory – securities and governance; anti-bribery and anti-corruption
  • Hotel development and management disputes
  • IT industry disputes
  • IP claims including counterfeiting, passing-off, copyright infringement
  • Mediation, Adjudication and Advocacy

PROFESSIONAL SUMMARY

Ashley has in excess of 23 years’ experience as a litigator and disputes lawyer. In his time at GRT Lawyers and working for top-tier Australian and global law firms (in the Middle-East and Singapore), Ashley has acted for clients across multiple continents on complex commercial litigation and international arbitration.

EXPERIENCE

Ashley’s current practice includes investment protection and dispute matters across a number of industry sectors including energy and resources, financial services, technology, agribusiness, tourism, in addition to contentious regulatory, insurance disputes and product liability matters.

The international scope of Ashley’s work has given him a valuable insight into cross-border disputes in common law and civil law jurisdictions. He has practical experience with most of the world’s renowned international commercial arbitration institutions including ICC, LCIA, SIAC, SCC and ICDR/AAA.

Since 2014, Ashley has been listed in ‘Best Lawyers in Australia’ Peer Review for the categories of International Arbitration, Litigation, Insurance and Product Liability.  In 2019, Ashley was added to the Doyle’s Guide Leading Commercial Litigation and Dispute Resolution Lawyers in Queensland.

QUALIFICATIONS

Ashley holds Bachelor Degrees in Law and Arts (University of New England) and he is:

  • a member of the Queensland Law Society (QLS)
  • Executive Council Member of Asia-Pacific Forum for International Arbitration (AFIA)
  • Associate Member of Australian Centre for International Commercial Arbitration (ACICA); and
  • ordinary member of Australian Insurance Law Association (AILA)
Director

Scott Standen

e scott.standen@grtlawyers.com
m 0447 790 009

EXPERTISE

  • In depth understanding of the M&A processes (public M&A and private M&A transactions)
  • Public equity capital markets transactions
  • Management of due diligence processes
  • Deep understanding of governance frameworks
  • Corporate structuring
  • Capital structure management
  • Transaction management
 PROFESSIONAL SUMMARY

Scott is a founder and Director of GRT Lawyers and GRT Foundation and corporate lawyer. He leads a team of specialist legal professionals, providing advice to organisations of all sizes, from middle market, large corporates and government owned corporations.

Scott’s career spans more than 20 years as a corporate lawyer and has encompassed an in-house general counsel role, director of Statutory Authorities and corporate legal adviser to managing directors, chief financial officers and boards of directors of ASX listed companies.

Scott is regularly called on by clients to provide strategic corporate advice to boards of directors and to project manage merger and acquisition transactions and public equity markets transactions. He prides himself in providing technically accurate and commercially focused corporate advice for public, private and listed companies, boards of directors and corporate advisers.

In particular, Scott advises on public equity markets transactions, debt issuances and restructuring, corporate governance and advisory, regulatory compliance, public and private M&A transactions, contract negotiation and directors’ duties and liabilities.

EXPERIENCE

Scott’s experience includes:

  • Advising Cerro Resources Limited in relation to its public market merger and acquisition deal with Canadian based Primero Gold Limited and the concurrent spin out of assets to Santana Metals Limited and listing of Santana Metals Limited on ASX
  • Advising Discovery Metals Limited in relation to its A$250 million debt restructuring and associated equity raisings and proposed convertible note issue
  • Advising Polymetals Limited in relation to its acquisition by Southern Cross Goldfields by way of scheme of arrangement
  • Advising Southern Cross Goldfields Limited in relation to its A$60 million capital raising transaction involving equity, debt and hybrid securities
  • Dual listing on Hong Kong Exchange of ASX listed company
  • ASX listing of Asia focused technology / media company and
  • ASX listing of Apiam Animal Health Limited, vertically integrated provider of services and product to agricultural industry and
  • ASX listing of P2P Transport Limited.

QUALIFICATIONS

Scott holds Bachelor Degrees in Law and Business Administration and a Masters of Law. Scott has previously held positions as a Director on the Boards of the Queensland Manufactured Water Authority (and related entities) and the Queensland Bulk Water Authority (and related entities).

Non-Executive Chair

Glenn Vassallo

e gv@grtlawyers.com
m 0422 857 760

EXPERTISE

  • Public capital markets
  • Corporate law
  • Private capital markets
  • Corporate advisory
  • Corporate structuring
  • Complex corporate disputes
  • Social entrepreneurship

PROFESSIONAL SUMMARY

Glenn is a founder of GRT Lawyers and the GRT Foundation. As the Non-Executive Chair of GRT Lawyers and the GRT Foundation, Glenn is passionate about working with his highly sophisticated national and international clients to implement their corporate strategy and solve their complex problems.

Glenn is passionate about implementing the corporate strategy of GRT Lawyers and the GRT Foundation. Glenn’s significant experience in formulating and executing complex corporate transactions (including IPOs, takeovers, and other equity capital market transactions) with a particular focus on national and international stock and security exchanges puts him in a unique position to provide excellent advice.

EXPERIENCE

After building GRT Lawyers into a high-quality law firm, and together with his wife Eliza, establishing the GRT Foundation into a sustainable Australian charity, Glenn built GRT App (a subsidiary of GRT Lawyers) and sold that to an ASX listed company. Glenn was the first chairperson of any Australian ASX listed company to successfully chair a real-time virtual meeting of shareholders. He is still today, the only person who has chaired a real-time virtual shareholders meeting for an ASX listed company.

Glenn is often invited to speak on global topics such as capital markets, initial public offerings, takeovers and more recently was invited to New York University to speak at its global conference about social entrepreneurship.

QUALIFICATIONS

Glenn holds a Bachelor Degree of Law (LLB) and a Bachelor Degree of Commerce. He has been a long-standing member of the Law Council of Australia Company Law Committee and the Queensland Law Society Company Law Committee, member of the Australian India Business Council (Energy and Resources – Subcommittee) and has significant ASX listed board experience.