Disclosure policy 

Standard 5.2b contains a recommendation on defining principles for the disclosure obligation, for instance, in the form of a disclosure policy. Such a policy paper consists of documenting the rules according to which a company communicates with the capital markets. It is important that this sort of policy document be drafted at the time the company is planning for listing. In its disclosure policy, the company identifies those responsible for investor relations, the way the company's future prospects are discussed, the type of guidance given to the markets, the circumstances under which a profit warning must be issued and, for example, what material information that must be disclosed under the Securities Markets Act generally means for the company. Besides the executive management, it is worthwhile for the board of directors to go through these matters.

A company's communication policy should be consistent and transparent so as to ensure that investors can reliably monitor developments in the company's performance. One key aspect required by the disclosure obligation is ensuring that any future prospects communicated to the markets are well-founded. This approach to the communication culture often requires new practices, which may take some time to put in place.

7 July 2009