Communications Policy

Bendigo and Adelaide Bank communicates with its shareholders by the following means.

• ASX announcements
  
• Quarterly shareholder newsletters
  
• Annual reporting
  
• Annual general meetings
  
• Shareholder question sheet included with annual general meetings notice
  
• Information on the Bendigo and Adelaide Bank website (see below)
  
• “e-shareholder” service, a facility through which shareholders are provided information (eg annual reports, notices of meeting etc) by email

The following material is made available on the Bendigo and Adelaide Bank website (www.bendigobank.com.au).

• Quarterly shareholder newsletters
  
• Annual review and full financial statements
  
• Media releases (for last three years)
  
• Notices of meeting (for last three years)
  
• Webcasting of results presentation (following preliminary final announcement)
  
• Webcasting of annual general meeting
  
• Any material provided in briefings with analysts, stockbrokers and institutional investors (that has not previously been released to the market).

In addition, there is a link from the Bendigo and Adelaide Bank website to the ASX website for access to announcements that Bendigo and Adelaide Bank has made to ASX.
In the case of AYT, announcements are available from the ASX website and the following materials are available from the AYT website (www.adelaidemanagedfunds.com.au).

• Research and product disclosure statements
  
• Annual and half year reports
  
• Investor presentations
  
• Webcasts
  
• Distributions
  
• Unitholder Updates
  

Notices: The annual general meeting notice provides for the appointment of proxies and a shareholder’s question form is included with the notice of meeting for shareholders to ask questions of the auditor and of the Board.

Chairman’s and Managing Director’s addresses: The Chairman’s address and Managing Director’s address are released to ASX before the meeting starts.

Auditors: The auditor attends the annual general meeting to answer questions.

Webcast: The annual general meeting is webcast on the Bendigo and Adelaide Bank website.

Direct Voting: Bendigo and Adelaide Bank has introduced direct voting to facilitate shareholder participation.

See Bendigo and Adelaide Bank Continuous disclosure policy.

In the case of AYT, see the Continuous disclosure compliance system policy.

See Bendigo and Adelaide Bank Continuous disclosure policy. In relation to persons who are authorised to speak with analysts, stockbrokers and institutional shareholders on behalf of Bendigo and Adelaide Bank, see 11 below.

In the case of AYT, see the Continuous disclosure compliance system policy

Bank releases: All information provided to the media, written and oral, must first be cleared by either the Managing Director or the General Manager, Marketing & Corporate Affairs (or a delegate).

In the case of a document prepared by the General Manager, Marketing & Corporate Affairs (or their delegate), the information must be cleared by the Managing Director (or the Executive Committee member with the responsibility for the matter the subject of the release).

In the absence of the Managing Director, clearance is by the Chairman.

AYT releases: In the case of AYT, all information provided to the media must first be cleared by the Board of AMF.

Franchise releases: All information provided to the media, written and oral, must first be cleared by the General Manager, Marketing & Corporate Affairs (or a delegate).

All releases: If an announcement is required to be given to ASX, it must not be given to the media before confirmation of its release by ASX – see Continuous disclosure policy. This includes giving information to the media on an embargoed basis.

Bank and AYT releases: The General Manager, Marketing & Corporate Affairs is responsible for the following.

• Preparation of media releases relating to Bendigo and Adelaide Bank and its subsidiaries.
  
• Making sure the information in media releases is accurate.
  
• Maintaining a register of all media releases and arranging for the releases to be made available on the Bendigo and Adelaide Bank website (or AYT website as the case may be).
  

Franchise releases: The franchisee is responsible for drafting the release and making sure the information is accurate. The General Manager, Marketing & Corporate Affairs is responsible for the following.

• Confirming the accuracy of the release.
  
• Maintaining a register of substantive media releases and arranging for those releases to be made available on the Bendigo and Adelaide Bank website.
  

The General Manager may delegate some or all of these responsibilities to the Head of Investor Relations.

All media enquiries, including requests for interviews, must be referred to the General Manager, Marketing & Corporate Affairs (or a delegate), or in his absence, the Managing Director (in the case of AYT, the AMF Board), before responding (and before agreeing to an interview).

The General Manager, Marketing & Corporate Affairs or Managing Director (in the case of AYT, the AMF Board) may elect to deal with the enquiry personally or refer it to the appropriate executive (eg a specialist such as Treasury or the relevant local branch manager).

Franchisees may comment on matters relating to the franchisee’s business provided no representation is made on behalf of Bendigo and Adelaide Bank.

Any matter relating to Bendigo and Adelaide Bank must be referred to the General Manager, Marketing & Corporate Affairs. The General Manager, Marketing & Corporate Affairs may elect to deal with the enquiry personally or authorise the franchisee to comment.

Bendigo and Adelaide Bank limits the number of persons authorised to speak on behalf of the Bank. This restriction applies across the categories set out below. The Bank also identifies a primary contact for each category.

Financial community

• Institutional Investors;
  
• Other investors;
  
• Analysts and stockbrokers;
  
• Media;

Regulators and rating agencies

• Australian Securities and Investments Commission;
  
• Australian Prudential Regulation Authority;
  
• Australian Stock Exchange;
  
• Australian Consumer and Competition Commission;
  
• Reserve Bank of Australia
  
• Austrac;
  
• Rating agencies;

Industry

• Australian Bankers’ Association;
  
• Banking and Financial Services Ombudsman; and
  
• Conferences.

This is to maintain control over the information that is provided and, in the case of information that is required to be disclosed to ASX, to reduce the risk of inadvertent disclosure to third parties before the information is given to ASX.

A list of authorised spokespersons is available from the Bendigo and Adelaide Bank website.

All authorised spokespersons must be familiar with the Continuous Disclosure Policy (in the case of AYT, the Continuous disclosure compliance system policy) and, in particular, make sure that no price sensitive information is disclosed before it is given to ASX and confirmation of release received from ASX.

If an authorised spokesperson who is not the primary contact for a particular category speaks on behalf of the Bank to third parties, that person is responsible for informing the primary contact of the communication.

No prospective, current or former officer, employee or contractor (including professional service provider) is constrained or impeded from disclosing information to APRA, from discussing issues with APRA of relevance to the management and prudential supervision of the Bendigo and Adelaide Bank, or from providing documents under their control to APRA, that may be relevant in the context of the management or prudential supervision of the regulated institution. Such persons are not constrained or impeded from providing information to auditors, and others, who have statutory responsibilities in relation to the regulated institution. This does not constitute speaking on behalf of the Bank and is not prevented by the authorised spokespersons policy.