Telstra 2009 Annual Report Download - page 59

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Telstra Corporation Limited and controlled entities
Corporate Governance Statement
• Where material information has originated in the
office of the CEO or the CFO or has been reported
directly to them, the CEO or CFO may, at their
discretion, seek the advice of, or a recommendation
from, the Committee in deciding whether to make or
approve an ASX announcement in relation to that
material information; and
• If the matter is disclosable, an announcement is
prepared and immediately sent via the Company
Secretary's office electronically to all relevant stock
exchanges.
Telstra has implemented several practices internally to
reinforce the importance of its continuous disclosure
obligations and the need to keep the Committee informed
about potentially disclosable matters. These practices are
reviewed regularly and include:
• Every Director is made aware of our continuous
disclosure obligations upon taking office and each
member of senior management undertakes training
with the General Counsel - Finance and Administration
or delegate, in relation to our continuous disclosure
obligations;
• A weekly email is sent to all senior management
reminding them to notify the Committee immediately
if they become aware of any potentially price-
sensitive information or proposals;
• The Committee maintains a list of issues which,
although not yet disclosable, are monitored in case
they become disclosable;
• All proposed media releases and external speeches
and presentations to be made by senior management
are reviewed by internal legal counsel to determine
whether they should be disclosed;
• A specific information paper is prepared for each Board
meeting summarising ASX announcements and
details of significant matters considered by the
Committee but judged not to be disclosable; and
• The Office of the Company Secretary maintains a
record of all market announcements made. The
announcements are also posted on our website after
market release is confirmed.
Telstra's Investor Relations Communication Policy governs
communications and the provision of information to
shareholders, brokers and analysts. The aim of this policy is to
ensure that we provide investors and the financial community
with appropriate and timely information whilst at the same
time ensuring that Telstra fulfils its statutory reporting
obligations under the Corporations Act and the ASX Listing
Rules.
Legal and Regulatory Compliance
Telstra is committed to conducting its business in compliance
with its legal and regulatory obligations. Compliance with
these obligations is not just a legal requirement but is integral
to the Company's commitment to its employees, customers,
shareholders and the community. Compliance is a key element
of the Telstra Values which are the foundation for the cultural
priorities and the way Telstra pursues its vision and mission.
Your Board and the senior management team are committed
to ensuring there is an appropriate compliance framework and
complementary controls in place to provide an appropriate
level of confidence that the Company is operating in
compliance with relevant laws, regulations and industry
codes. This is achieved through the Compliance & Corporate
Ethics Framework (the C&CEF). Your Board has given the Audit
Committee specific responsibility for reviewing Telstra's
approach to achieving compliance with laws, regulations and
associated industry codes in Australia and overseas and for the
general oversight of compliance issues. This oversight is
facilitated by the preparation of a regular and comprehensive
compliance report highlighting aspects of the C&CEF and
summarising our compliance initiatives and issues.
The C&CEF brings together Telstra's business units and the
individual subject matter specific compliance programs in an
integrated, consistent and collaborative way.
Telstra has adopted a comprehensive program-based
approach to compliance. This has been fundamental to its
approach to compliance for many years and this continues to
be a key element of the C&CEF. Subject matter experts work
with the business to help understand the many legal and
regulatory obligations and responsibilities faced by the
Company and translate them into appropriate practice. There
are currently 14 programs under the C&CEF including health
and safety, environment, privacy, trade practices, diversity,
disability, fraud, industry regulation, information security,
operational separation, financial reporting, records
management, whistle-blowing and continuous disclosure.
This program-based approach at a corporate level is supported
by a network of senior personnel appointed to the role of
Business Unit Compliance Manager. They are, in turn,
supported by other personnel at the business unit level with
specific responsibility for the implementation of the
compliance programs within their business unit. This structure
has been designed with the aim of ensuring that each business
unit's operations are conducted in accordance with the
Company's obligations in an efficient, effective and integrated
manner that reflects that business unit's individual compliance
risk profile.