Shareholder Re-engagement Campaign
Phased campaign to re-engage ~207 shareholders after a prolonged governance gap (no AGMs, no formal communications, no financial reporting to members). This is a prerequisite for the capital raise and structural reform. Source: Shareholder Re-engagement Research.
April 2026 update (10-tab registry analysis): The “48% without email” figure was based on Tab 1 of the registry. Tab 5 (dedicated email lookup) contains 199 emails — confirming ~96% coverage of shareholders (Apr 2026 direct analysis). The re-engagement campaign shifts from “find contact details” to “re-establish relationship.” See Shareholder Registry and Email Analysis.
Why This Must Happen Before the Capital Raise
- s 113 breach must be resolved first — the capital raise is structurally impossible under the current Pty Ltd form. See Corporate Structure Breach.
- Structural conversion requires a shareholder vote — special resolution (75%) for public company conversion, or two-thirds majority for cooperative formation. Email coverage is confirmed at 96% (199 of 207), but email alone doesn’t constitute engagement — re-establishing the relationship is essential for achieving quorum and informed voting.
- Re-engaged shareholders are the foundation for capital raise communications — shareholders who have been genuinely reconnected are far more likely to participate or refer new investors.
Privacy Law: What Is and Isn’t Permitted
Permitted
- Collecting emails for register administration — “reasonably necessary” under APP 3 (no separate consent)
- Third-party contact tracing where direct collection becomes “impracticable” (returned mail)
- Correcting out-of-date information — proactive obligation under APP 13
- Using existing register data (name, address, phone) for outreach
Not Permitted
- Collecting sexual orientation or gender identity data (sensitive information under s 6(1))
- Marketing communications beyond register admin without separate Spam Act consent (include unbundled opt-in on update forms)
LGBTQ+-Specific Safeguards
- Use preferred names in all correspondence; legal names maintained separately on register
- Process name changes without requiring explanation
- Plain envelopes without venue name for physical mail
- Private messages not public tags for social media outreach
- Staff/volunteer training on deadnaming and sensitive data handling
Share Champions Programme
Recruit 5–15 engaged shareholders as community ambassadors to personally contact dormant shareholders they already know. This is the highest-trust outreach method for LGBTQ+ communities.
Rules:
- Champions do NOT receive the shareholder register
- Champions only contact people within their existing personal networks
- Champions receive a brief, talking points, and an update form link — not confidential data
- Proven in UK community shares movement (Plunkett Foundation) and academic community engagement research
Phased Campaign
| Phase | Timeframe | Actions |
|---|---|---|
| Preparation | Weeks 1–4 | Audit register. Segment 8 no-email shareholders by postal validity and phone availability. Recruit 5–10 share champions. Build online update form with APP 5 privacy notice. Prepare shareholder event. |
| Initial Outreach | Weeks 5–8 | Post letters with QR code and prepaid reply envelope. Call shareholders with phone numbers on file. Activate share champions. Social media announcement. Venue signage. |
| Follow-Up | Weeks 9–16 | Second letter to non-respondents. Champions make second contact. Host shareholder event — capture details at door. Search public records for returned-mail addresses. |
| Decision Point | Weeks 17–24 | Review results. Offer share withdrawal to remaining unreachable shareholders. Assess against 3-year dormancy rule (co-op) or 6-year s 1343 rule (company). Document all contact attempts for compliance. |
| Ongoing | Permanent | Annual detail confirmation at AGM. QR code at venue for updates. Preferred name field in database. |
Handling Unreachable Shareholders
After the campaign, some shareholders will remain unreachable. Legal mechanisms:
| Structure | Mechanism | Timeline |
|---|---|---|
| Company (current) | s 1343 — transfer securities to ASIC as unclaimed property | After 6 years of documented inability to contact |
| Company (current) | September 2023 amendments — cease communications to “lost members” | After genuine attempt within 6–18 month window |
| Cooperative (if converted) | Board cancels inactive memberships | After 3 years of inactivity/unknown whereabouts, with 28 days’ notice. 1-year deferral by ordinary resolution. |
Key point: All mechanisms require documented contact attempts. The phased campaign generates this documentation.
Digital Governance Tools
Recommended: Registry Direct Standard ($150/mo)
Self-service share register, shareholder communications, voting, ASIC reports, 14-day free trial. Replaces any existing spreadsheet-based register. Alternatives: Orchestra ($400/mo, Xero integration) or Syndex (cooperative-specific, BCCM-endorsed).
Minimum Viable Governance Stack (~$2,150/yr)
| Tool | Purpose | Cost |
|---|---|---|
| Registry Direct Standard | Register, comms, voting | $1,800/yr |
| Campaign Monitor (pay-per-campaign) | Quarterly newsletters | ~$47/yr |
| Zoom | Hybrid AGM | ~$300/yr |
Enhanced Stack (~$5,700–$6,700/yr)
Adds: Registry Direct Premium (dividends, ATO), Loomio Pro (~$780/yr for async decision-making), TrueVote (formal AGM voting).
Hybrid meetings are permitted for all entities without constitutional change since the Corporations Amendment (Meetings and Documents) Act 2022. Virtual-only requires express constitutional clause.
Communication Strategy for Re-engagement
The Critical Sequence (After Governance Gaps)
- Acknowledge what happened — be specific about the gap in communications
- Explain what has changed and what safeguards are in place
- Demonstrate through consistent action over months, not words
- Invite two-way feedback before asking for anything
- Celebrate only after trust rebuilt through sustained effort
Attempting to re-engage without naming the governance gap honestly will fail. This is the most consistent finding across UK community pub, Bendigo Community Bank, and cooperative governance research.
Content Mix
80% community/educational content, 20% operational updates. Community-focused email achieves 47% open rates vs 35% for product-focused content. The annual report structure (Bendigo model): chair’s report (personal, accessible), manager’s report (operational highlights), community contribution summary (quantified impact), board profiles, financials, forward priorities.
Recommended Cadence
| Communication | Minimum | Optimal |
|---|---|---|
| Newsletter / member update | Quarterly | Monthly |
| Financial update | Annually | Semi-annually |
| AGM / member meeting | Annually | Annually + 1–2 extraordinary |
| Impact report | Annually | Annually |
| Member survey | — | Annually |
Channel Strategy
- Email: Highest-ROI owned channel — now confirmed at ~96% coverage (199 of 207 shareholders per Tab 5 analysis, April 2026)
- Physical mail: Essential for the ~8 shareholders without email on file, and for legally required notices (meeting notices under ss 249H–249J must be sent to registered addresses)
- Facebook: Primary social platform for community enterprises
- SMS: Must register with ACMA Sender ID Register before July 2026
- Member portal: Reduces admin burden (Registry Direct or Syndex)
Dependencies and Sequencing
Audit register (Week 1–4)
↓
Launch re-engagement campaign (Week 5–16)
↓
Achieve >75% contact rate (Week 17–24)
↓
Hold structural conversion vote (Month 4–8)
↓
Complete conversion to co-op or public company
↓
Launch capital raise
The campaign must achieve sufficient engagement — not just contact coverage — to legitimise the structural conversion vote. Email coverage is confirmed at 96%, but shareholders who haven’t heard from the company in years need re-engagement before they can cast an informed vote. A poorly attended vote creates governance risk and potential challenge grounds.
Key Facts
- ~4% of shareholders (~8 people) have no email address on file (199 of 207 confirmed via Tab 5)
- Privacy law (APP 3) permits email collection for register administration without separate consent
- SOGI data must NOT be collected (sensitive information under Privacy Act)
- Share Champions (5–15 volunteers) are the highest-trust outreach method for LGBTQ+ communities
- Registry Direct Standard ($150/mo) is the recommended digital registry platform
- Minimum viable governance stack: ~$2,150/yr
- Hybrid meetings permitted without constitutional change since 2022
- s 1343 allows transfer of unreachable shareholders’ securities to ASIC after 6 years
- Co-op rules allow cancellation of inactive memberships after 3 years with 28 days’ notice
- Communication sequence: acknowledge gap → explain changes → demonstrate → invite feedback → celebrate
- 80/20 content rule: community content vs operational updates
Related Pages
- Shareholder Re-engagement Research — source document
- Corporate Structure Breach — s 113 breach (must resolve before capital raise)
- Corporate Structure Reform — conversion decision
- Co-operative Conversion Pathway — recommended conversion process
- Shareholder Engagement — broader engagement strategy and Founders programme
- Shareholder Communication Strategy — comms framework
- Shareholder Structure and Rights — register data and contact gaps
- Governance Gaps and Risks — governance remediation context
- Capital Raise Strategy — why re-engagement is prerequisite
- Community-Owned Venue Economics — Bendigo, Hepburn, UK models