6 June 2013

Manager
Corporate Governance and Reporting Unit
Corporations & Capital Markets Division
The Treasury
Langton Crescent 
PARKES ACT 2600

Submission from Guerdon Associates re Schedule 4 – Amendments of the Corporations regulations 2001

Thank you for the opportunity to comment on the exposure draft of Schedule 4.

Our submission includes brief background on Guerdon Associates and feedback regarding specific aspects of the draft.

Guerdon Associates

Guerdon Associates is Australia’s largest independent executive remuneration consulting firm.  Consulting staff are located in Melbourne and Sydney, with additional support located in offices in Chennai, India (database management and administration) and San Francisco (technology support).

Suggested amendments to Schedule 4

We suggest amending the draft regulation as follows:

Page	Item	Amendment	
5	18	Replace “rights and options” at the end of the Condition, with “equity instruments” as this paragraph is dealing with equity instruments other than options and rights.	
5	18, (a) through (f)	Replace “Options and rights” at the beginning of each subparagraph with “Equity instruments	

Yours sincerely,

Michael Robinson
Director