According to the regulator’s findings, several of Bright Dairy’s internal systems failed to meet required standards. Key governance documents—including its revised 2024 Articles of Association and board procedures—contained provisions that did not align with official guidelines for listed companies, particularly in areas such as external guarantees, shareholder voting, and the appointment of accounting firms.

Further compliance gaps were identified in board operations. Between 2024 and May 2025, the company failed to properly document minutes from board and committee meetings conducted electronically, breaching rules governing independent directors. In addition, procedural violations occurred in 2025 when an audit committee meeting was held after a board meeting to review a chief financial officer appointment, contravening established governance protocols.

Disclosure and information management practices also raised concerns. Between 2023 and 2024, Bright Dairy did not adequately register insider information, failed to confirm responsible parties, and recorded incomplete details in key event filings. These shortcomings extended to major financial matters, including asset impairment provisions and capital activities linked to its subsidiary, Synlait Milk Limited.