Listed Markets
Counsel for ASX-listed entities, large and small. Disclosure judgements, corporate actions, transactions, and the JORC and Chapter 5 overlays that complicate resources disclosure.
Disclosure obligations for listed entities are among the most complex regulatory regimes in Australian law. For mining and resources entities, the mandatory JORC Code and Chapter 5 overlays add a further layer that intersects with, and often complicates, the standard Listing Rules and Corporations Act requirements. Continuous disclosure judgements, market-sensitive announcements, periodic reporting, capital raising disclosures and transaction documents all need to land correctly the first time.
Where many firms hesitate at the technical elements of mineral asset disclosure, or focus only on the narrower pieces, this is where we operate. Our lawyers bring backgrounds across finance, mining and regulation, which means transactions and disclosures are handled holistically: the financial reporting question, the resource estimate disclosure question, and the Listing Rule question are all delivered by a single experienced adviser.
The same expertise applies to day-to-day obligations and to transactions: continuous disclosure decisions, JORC announcements, secondary raisings, takeovers, schemes of arrangement, M&A, shareholder agreements, commercial contracts and due diligence. Our principal stays on the matter from initial advice through to execution.
When a regulator makes contact — a query, a request for information, or a formal enquiry — it can pull focus from the core business at exactly the wrong time. This is where the team's background matters most. Having sat on the regulator's side of these conversations at ASIC and Treasury, we develop response strategies that align with the company's commercial objectives while addressing what the regulator is actually concerned about. The two are not always the same, and managing the gap is the work.
When clients engage this practice.
ASIC, ASX or another regulator with a query, RFI or formal enquiry. Response strategy that aligns with commercial objectives while addressing what the regulator is actually concerned about.
JORC sign-off, continuous disclosure threshold, timing decisions. Sat alongside the disclosure committee or running the call ourselves.
Chapter 5 disclosure, JORC consistency across previous filings, sensitivity tests, table compliance.
Cleansing notice, prospectus exception strategy, capital structure work, shareholder approval timing.
Chapter 6 strategy, FIRB intersection, deal architecture, scheme booklet, takeover defence. Named principal across the whole matter.
- Continuous disclosure & regulator response
- Listing Rules compliance (all chapters)
- IPOs, secondary raisings & placements
- Takeovers, schemes, M&A
- JORC code & Chapter 5 resources disclosure
- Board advisory on market-sensitive matters
- Shareholders agreements & capital structure
- Commercial contracts & transaction due diligence
We sit on the call, document the materiality assessment, time-stamp the reasoning, and draft the announcement if it lands above the threshold. The work is structured to be defensible if the regulator later asks how the decision was made.
Yes — core to the practice. Direct regulatory background in mining and resources disclosure standards, so the advice reflects both the rule and how ASX and ASIC actually read it.
It changes what gets emphasised, what gets included, and what gets left out. Regulators read responses against patterns they've seen before. Knowing the pattern — and where this matter sits in it — is the difference between an outcome that closes cleanly and one that escalates.
Engage the Listed Markets practice.
Named principal on every matter. Senior advice. No junior hand-offs.