TIMELY & BALANCED DISCLOSURE
(Corporate Governance Recommendation 5.1)


1. Introduction

As a company whose shares are traded on the Australian Stock Exchange (ASX), Immuron has an obligation to ensure that the market is both fully and accurately informed about material matters by timely and balanced disclosure.

The ASX requirement for ‘continuous disclosure’ of material and price sensitive information ensures that all investors and other stakeholders are treated equally. The information disclosed is to be factual and presented in a clear and balanced way. ‘Balance’ requires disclosure of both positive and negative information.

In order to ensure that this occurs it is important that only authorised officers make statements which could affect the share price and the financial markets understanding of the Company and its activities.

The following has been prepared to assist company officers in applying these principles.

2. Discussion

There has always been a need to carefully control the way that information about the Company’s activities gets into the market place. The Australian Securities and Investment Commission (ASIC) have a surveillance monitoring program to minimise unexplained price and volume movements.

There is a wide variety of parties who are constantly seeking information about the Company. These include shareholders, media (all forms), stockbrokers/analysts, fund managers competitors and the public.

To ensure that only information that is accurate, balanced and consistently given is publicly available, all directors, officers and contractors should have in mind the following policy at all times.

The following policy includes all material that is available to the public including information on the company’s website.

3. Policy

The Company will make written announcements to ASX as quickly as possible on any matter which, in the opinion of the directors or chief executive officer, is material and/or could be considered to be price sensitive.
Except to the extent required to carry out their duties, company officers and contractor are not permitted to provide any information about the past, current or future activities of the Company. In particular staff and contractor must not discuss anything to do with the Company’s activities with the media, stockbrokers/analysts and fund managers. Non-business enquiries from shareholders and the public should be directed to the people listed below.
The only people authorised to speak on the affairs of the Company or make written public announcements are:
The chairman, the chief executive officer or
Persons delegated from time to time by the chairman or chief executive officer, or
in the case of authorised written announcements, the company secretary
Due to the seriousness of the matter anyone who does not adhere to this policy could be subject to dismissal.
4. Procedure

The chief executive officer is primarily responsible to ensure that this Policy is adhered to. Other directors should raise any matters of concern with the chairman.
Once the chief executive officer has become aware that any material matter has occurred, or is likely to occur in the near future, which could impact on the share price he/she will immediately;
Verify the facts of the matter,
Arrange for a draft announcement to be prepared,
Ensure that the draft is factual, does not omit any material information (either positive or negative) and is clear and objective,
Circulate the draft to all directors who are to respond immediately,
After consultation with the chairman, (or at least one other director if the chairman is not available) release the agreed announcement to ASX, and
After receiving ASX confirmation, put the announcement onto the Company’s website and advise senior staff.
The agenda for every board meeting will include an item dealing with compliance with this Policy.
The chief executive officer will ensure that company officers and contractors are aware of this Policy and that measures are taken to avoid emergence of a false market and ensure the safeguarding of confidential information.
Analyst briefing and responses to shareholder and others will only cover those matters that have previously been released to the public.
Amended by the board of Anadis Limited 16 June, 2004.