Disclaimer & Editorial Policy

Updated 14 May 2026

This Disclaimer governs all Content published on Thesis Tracker. It is incorporated into the Terms of Use by reference. Please read it carefully before using the Service. In the event of any inconsistency between this Disclaimer and the Terms of Use, this Disclaimer prevails.

1. About this Disclaimer

This Disclaimer applies to all Content published on Thesis Tracker (the "Service"). By accessing the Service, you confirm that you have read and accepted this Disclaimer.

2. Plain-language summary

If you read nothing else, please read this section.

Thesis Tracker is a record of what Australian fund managers have publicly said about ASX-listed companies. It is an information service, not a financial advice service.
Each entry on the Service consists of a short factual statement of what the manager did (initiated, increased, reduced, exited, or held a position) and one or more passages quoted directly from the manager's own published materials.
The Operator does not author opinions, recommendations, ratings, or evaluations. Quoted passages are the fund manager's own words.
Where a fund manager's published material raises both supportive and counterbalancing points about a security, the Operator includes quotations reflecting both — or flags the entry for human review if a faithful entry cannot be produced.
The Operator does not hold an Australian Financial Services Licence and is not authorised to give financial product advice.
Content on the Service is not, and must not be treated as, the basis for any investment decision. The original Source Materials, and licensed financial advice, are the appropriate inputs to investment decisions.
Fund managers can be wrong. Their views are made at a point in time and may quickly become out of date. Past performance and prior positions are not a guide to the future.
Investing in financial products involves risk, including the risk of losing money.

3. What the Service is

3.1 An information service

Thesis Tracker exists to make publicly available statements by Australian fund managers easier to find and read in context. It is the kind of service that catalogues primary-source material — like a public records database, a regulatory filing index, or a news archive — rather than the kind of service that analyses, interprets, or recommends.

3.2 The structure of each Entry

Each Entry on the Service consists of:

identifying metadata — the Fund Manager, the source publication, the publication date, the entity to which the statement relates, and a direct link to the source publication where it is publicly available;
an Action Statement — a single factual sentence describing the portfolio action the Fund Manager has reported (such as "initiated a position", "increased their holding", "reduced their holding", "exited their position", "made no change to their position", or "commented on");
one or more Verbatim Extracts — passages copied exactly from the source publication, reproduced in quotation marks with attribution to the Fund Manager. The total length of Verbatim Extracts in an Entry is typically between 40 and 250 words, depending on how much of the source is needed to represent the substance of what the Fund Manager said;
optionally, a Topical Sentence — a single sentence in neutral, non-evaluative language identifying the subjects the source publication discusses; and
descriptive topical tags identifying subjects discussed in the source publication.

3.3 The Operator does not author commentary

The Operator does not write its own analysis of any security, fund manager, or fund. The only operator-authored content in any Entry is the Action Statement (factual, describing the portfolio action) and, where included, the Topical Sentence (describing the subjects the source discusses, in neutral language). All substantive content describing what the Fund Manager said, why, or with what expectation is presented as a Verbatim Extract — the Fund Manager's own words.

4. What the Service is not

4.1 Not financial product advice

Nothing on the Service constitutes financial product advice — personal or general — within the meaning of s766B of the Corporations Act 2001 (Cth). The Service does not provide recommendations, opinions, ratings, or endorsements in relation to any financial product, security, fund, or service.

4.2 No AFSL

The Operator does not hold an Australian Financial Services Licence and is not an authorised representative of an AFSL holder. The Operator is not authorised to provide financial product advice.

4.3 Your circumstances not considered

Content has been prepared without taking into account your objectives, financial situation, or needs. The Service cannot, and does not, consider whether any statement recorded on it is appropriate for any particular user.

4.4 Not research, not ideas

The Service is not:

a research service, investment newsletter, or tipsheet;
an investment idea generator;
a "follow the smart money" or copy-trading service;
a model portfolio or asset allocation service;
a thesis writer or recommendation engine; or
a substitute for the original Source Materials, a Product Disclosure Statement, a Target Market Determination, or advice from an appropriately licensed financial adviser.

4.5 No sentiment scoring, no ratings, no rankings

The Service does not publish sentiment scores, ratings, rankings, "bullish percentages", evaluative summaries, price targets, forward-looking statements about specific securities authored by the Operator, or any other output that would suggest the Operator's view of the merits of a Fund Manager, fund, or security.

4.6 Forward-looking content in Verbatim Extracts

Verbatim Extracts may contain forward-looking statements, projections, targets, or opinions where those appear in the source publication. Such content reflects the Fund Manager's view at the time of publication and is subject to the Fund Manager's own qualifications and risk warnings. It is not the Operator's view. Fund managers are frequently wrong about forward-looking matters, and you should not treat forward-looking content within a Verbatim Extract as a reliable guide to actual future outcomes.

4.7 Not a basis for investment decisions

Content on the Service must not be used as a basis for any investment decision. Any investment decision must be made on the basis of the original Source Materials, the relevant Product Disclosure Statement and Target Market Determination, your own assessment of those documents against your own circumstances, and advice from an appropriately licensed financial adviser.

5. Editorial Policy

5.1 Purpose of this Editorial Policy

This Editorial Policy describes the operational practices that distinguish Thesis Tracker as an information service. The commitments in this Policy are binding on the Operator and are reviewed at least annually. The integrity of the Service depends on these commitments being operationally real.

5.2 Source selection

The Operator records statements made by Australian fund managers in publicly available source publications, including monthly reports, quarterly updates, investor letters, annual reviews, and public interviews. Sources are selected on the basis of relevance to Australian listed entities, public availability, and the practicality of producing a faithful Entry. The Operator does not pay for inclusion of any source, and no source pays for inclusion, prominence, or favourable treatment on the Service. The Operator has no commercial relationship with any Fund Manager whose statements are recorded on the Service, except where expressly disclosed on the relevant Entry.

5.3 Attribution

Every Entry is attributed to its source. Attribution includes the name of the Fund Manager, the publication in which the statement appeared, the publication date, and a link to the original publication where it is publicly available. The Operator does not publish anonymous, unattributed, or speculatively-sourced Entries.

5.4 Faithfulness commitment

The Operator commits to representing source publications faithfully. The following operational rules implement this commitment:

Verbatim Extracts are verbatim. A Verbatim Extract is copied exactly from the source publication, preserving the Fund Manager's wording. A Verbatim Extract may not be paraphrased, condensed, smoothed, or improved. A Verbatim Extract may not stitch together non-adjacent passages from the source within a single quotation.
Counterbalancing considerations are included. Where the source publication raises a material counterbalancing consideration — a concern, a risk, a hedging factor, or any other point that would materially qualify the impression conveyed by other Verbatim Extracts in the Entry — the Operator either includes an additional Verbatim Extract capturing that consideration, or applies NEEDS_REVIEW status to the candidate Entry.
NEEDS_REVIEW. Candidate Entries that cannot be faithfully represented under (a) and (b) are flagged NEEDS_REVIEW and held back from publication until reviewed by a person. Following review, the reviewer either composes a faithful Entry (typically by selecting additional or replacement Verbatim Extracts), declines to publish the Entry, or refers it to the source Fund Manager for guidance.
Topical Sentences reflect the source. Where a Topical Sentence is included in an Entry, it identifies the range of subjects the source publication discusses, in neutral non-evaluative language. The Topical Sentence may not selectively name only subjects that support a particular impression of the Fund Manager's view.

5.5 Verbatim Extracts and Action Statements

An Entry consists of an Action Statement (a single sentence factually describing the Fund Manager's portfolio action) and one or more Verbatim Extracts (passages copied exactly from the source publication). The Action Statement is the Operator's only authored substantive content in an Entry. It does not extend, qualify, evaluate, or interpret what the Fund Manager said. Reasons for the portfolio action, where stated in the source publication, are reproduced verbatim within Verbatim Extracts — they are not paraphrased into the Action Statement.

5.6 Topical Sentences

An Entry may include a Topical Sentence — a single sentence in neutral, non-evaluative language identifying the subjects the source publication discusses. Topical Sentences:

use descriptive nouns and noun phrases (for example, "above-rail volume performance", "the proposed regulatory extension", "concerns about the iron ore price outlook");
do not use evaluative descriptors (for example, "positive view on", "optimism about", "concerns over" — though "concerns about" used as a neutral noun phrase is acceptable where the source raises a concern);
are omitted from an Entry where they cannot be written without evaluative drift.

5.7 Review processes

The Operator maintains the following review processes:

Verbatim verification. Verbatim Extracts are checked for exact-match correspondence to the source publication. Extracts that are not substring-matchable to the source are corrected or replaced before publication.
Faithfulness review. Entries are reviewed for compliance with the faithfulness commitment in clause 5.4 before publication, with particular attention to whether material counterbalancing considerations from the source are represented.
Classification review. Action classifications and topical tags are reviewed for accuracy and for compliance with the prohibitions on evaluative content.
NEEDS_REVIEW workflow. Entries flagged NEEDS_REVIEW are reviewed by a person before publication. The reviewer's decision (publish, decline, refer to the Fund Manager) and the rationale is recorded internally.
Periodic audit. The Operator conducts a periodic audit of published Entries against their source publications, sampling at least 5% of Entries published in each calendar quarter. Audit findings are recorded and any systematic issues identified are addressed through changes to processes or to specific Entries.
Source updates. Where a Fund Manager publishes a correction, retraction, or updated statement relating to material previously recorded on the Service, the Operator updates or annotates the relevant Entry within a reasonable time.

5.8 Use of automated tools

The Operator uses automated tools to assist in extracting Verbatim Extracts and drafting Action Statements and Topical Sentences from source publications. Automated outputs are reviewed by a person before publication in accordance with clause 5.7. The Operator does not publish Entries that have not been subject to human review.

5.9 Corrections and takedowns

The Operator publishes a Complaints, Takedown and Corrections Policy describing how users and Fund Managers may request corrections or removal of Content. Fund Managers may request removal of any Content sourced from their materials at any time, without giving reasons. Removal requests are actioned within 5 business days of receipt.

5.10 What the Operator does not publish

To preserve the integrity of the Service as an information service, the Operator does not publish:

sentiment scores, "bullish percentages", or other evaluative summaries derived from Fund Manager statements;
ratings, rankings, or "Top X" lists of Fund Managers or securities;
price targets, forecasts, or other forward-looking statements about specific securities authored by the Operator;
"why fund managers like X" framings, "investment ideas", "tips", or other content designed to direct users toward specific investment actions;
model portfolios, suggested allocations, or asset selection guidance;
comparative analyses suggesting one Fund Manager, fund, or security is better than another;
personalised content tailored to any user's circumstances;
analysis or commentary authored by the Operator about the merits of any security; or
paraphrases or summaries of a Fund Manager's investment thesis written in the Operator's own words.

5.11 Independence

The Operator does not accept payment, advertising, sponsorship, or other consideration in exchange for inclusion, prominence, or favourable classification of any Fund Manager or security. Where any commercial relationship exists between the Operator and a Fund Manager named on the Service, that relationship is expressly disclosed on every page where the Fund Manager appears.

5.12 Changes to editorial practice

This Editorial Policy is reviewed at least annually. Material changes are notified to users via the Service and email. The Operator maintains a version history of the Editorial Policy.

6. No warranty of accuracy

6.1 Accuracy not guaranteed

The Operator does not guarantee the accuracy, completeness, currency, or reliability of any Content. Content is compiled from third-party source publications and may contain errors, omissions, or out-of-date information. While the Operator's editorial processes (described in section 5) are designed to support faithful representation, no system is perfect.

6.2 Always check the Source Material

Before relying on any Content, you should read the original source publication in full, consider the date the statement was made, check whether more recent statements have been published, and consult any disclaimers or risk warnings published by the source Fund Manager.

6.3 Information may be outdated

Statements published by Fund Managers are made at a particular point in time and reflect the manager's views at that time. Subsequent events, market conditions, and changes in the manager's portfolio or views may render earlier statements outdated or no longer reflective of the manager's current position. The Operator does not update Content to reflect such changes unless the source Fund Manager publishes a corresponding update.

6.4 Corrections

If you identify a material error in any Content, please contact team+corrections@thesis-tracker.com. The Operator's process for handling corrections is set out in the Complaints, Takedown and Corrections Policy.

7. Risk warnings

7.1 You can lose money

Investing in financial products involves risk, including the risk of losing some or all of the money you invest. Markets can fall as well as rise. Individual securities can fall to zero. Markets and individual securities can move sharply and unexpectedly.

7.2 Past performance is not a guide

Past performance — of a Fund Manager, a fund, a security, or a market — is not a reliable indicator of future performance. Fund Managers who have performed well historically may underperform in the future. Fund Managers who hold particular securities may sell them at any time.

7.3 Fund managers can be wrong

Statements published by Fund Managers reflect their own views and judgements, which can be — and frequently are — wrong. Holding a security in a portfolio does not mean that security will perform well. A Fund Manager who is positive about a security at the time a statement is published may have sold the security, or revised their view, by the time you read about it. Forward-looking statements within Verbatim Extracts (such as expected earnings, projected outcomes, or targets) are the Fund Manager's view at the time of publication — not predictions of actual outcomes.

7.4 Speculative and concentrated risks

Some of the securities discussed on the Service are small-capitalisation, speculative, illiquid, or otherwise carry concentrated risk. These securities can be especially volatile and especially vulnerable to loss of capital.

7.5 No reliance

You should not rely on any Content as a basis for making investment decisions. Decisions should be made on the basis of the relevant Product Disclosure Statement and Target Market Determination, the original Source Materials, your own assessment of the relevant product against your own circumstances, and advice from a licensed financial adviser.

8. Getting financial advice

If you require financial product advice, please consult an appropriately licensed financial adviser. Licensed financial advisers in Australia are listed on the ASIC Financial Advisers Register at moneysmart.gov.au. The Operator does not endorse any particular adviser and cannot make a recommendation to you about which adviser to use.

9. Limitation of liability

To the maximum extent permitted by law, the Operator excludes all liability for any loss or damage (including investment loss, opportunity cost, and consequential loss) arising out of or in connection with any reliance on Content. The limitation of liability provisions in clause 11 of the Terms of Use apply to all use of the Service and all Content. Nothing in this Disclaimer excludes, restricts, or modifies any consumer guarantee, right, or remedy conferred by the Australian Consumer Law or any other law that cannot lawfully be excluded, restricted, or modified.

10. Changes to this Disclaimer

The Operator may amend this Disclaimer from time to time. The current version is always published on the Service. Continued use of the Service after the effective date of an amendment constitutes acceptance of the amended Disclaimer.

11. Contact

For questions about this Disclaimer or the Editorial Policy, please contact team@thesis-tracker.com. For corrections, contact team+corrections@thesis-tracker.com. For takedown requests, contact team+request@thesis-tracker.com.