Information/Communications Policy - Cordovan Group AB (publ)
Cordovan Group's external reporting/accounting material and investor relations (IR) will be characterized by the greatest possible openness, excellent reliability, good accessibility and rapidity.
Corporate managers and every member of the board – as well as employees working with the company's financial information – should all without exception promote the quality of our communications on the basis of their knowledge and the information available to them. We must continuously strive to formulate information so that it is readily digestible by the recipient and also otherwise duly corresponds to the demands of the stock and finance market.
Responsibility
The MD is responsible for the company providing information and investor relations (IR) in accordance with this Policy.
Production of external reporting/accounting and information material
Reporting/accounting information will be prepared by the company's staff in accordance with routines laid down by the MD. Documentation for interim reports, year-end reports and annual reports must be submitted to members of the board approximately one week prior to the announced date of publication. The board will deliver these reports.
Press releases will be produced by the MD, or the person that he/she appoints in her/his place (head of communications or the like), when necessary in collaboration with an external PR firm. If an external party is engaged to produce a press release, such a party must complete a confidentiality undertaking and be informed that any employees involved are subject to the insider provisions.
Distribution of reporting/accounting information and press releases
External reporting/accounting information, interim reports and year-end reports shall be publicized in accordance with the regulations of the Stockholm Stock Exchange.
We aim to create a sound, fair and reliable basis on which the stock market can assess the share of the Cordovan Group. A fundamental precondition for achieving this is that all important contracts, events or decisions that may affect the valuation are publicized immediately – as soon as it is practically possible to do so.
When working with information, a balance must be made between the obligation to provide shareholders and other interested stakeholders with information, the right to postpone the release of information for commercial or other reasons and the obligation to treat all shareholders and other stakeholders equally. Risks associated with selective communications should always be taken into account.
In the event that the information is considered to be borderline as regards influencing the price of the share, it should always be publicized.
It is the policy of the company not to disclose forecasts regarding future earnings trends. If the company considers that the market's own forecasts are unrealistic, the company must investigate whether the market has misunderstood the company's information and, in serious cases, correct this misunderstanding by means of a press release. However, individual analysts may not be contacted as this may be deemed to comprise a special communication of information.
Annual reports will be publicized on the company's website. Printed annual reports will be distributed to those shareholders who have indicated such wish via the VPC (securities registration centre).
Contacts with the media
Contacts with the media will be conducted by the MD, or through employees appointed by the MD in each individual case. However, individual employees may express views in specialist professional publications concerning matters relating to professional subjects. Employees should refer to the company's MD as regards all other matters.
Contacts with capital market stakeholders and shareholders
Contacts with analysts, institutional shareholders and other capital market stakeholders will be conducted by the MD, or through employees appointed by the MD in his place.
The company's CFO will participate in any detailed presentations of financial reports.
The following is permitted as regards contacts with analysts:
- to provide a reminder of previous information publicized
- to substantiate previously publicized information
- to correct obvious misunderstandings and arithmetical errors
- to provide sector statistics
Information that may affect the price of the share may be provided at analyst meetings, whether an ordinary meeting or a telephone or web conference, provided the company issues a press release at the same time.
If the company mistakenly provides information at such a meeting that may affect the price of the share, for example, as a response to an unexpected question, a press release shall be distributed to other stakeholders without any unnecessary delay.
If an analyst has received certain information, the company cannot refuse to provide another analyst or journalist with the same information.
There is no such thing as 'off the record'; all information provided to a journalist should be regarded as public.
Contacts with private shareholders must be dealt with by the MD, the chair or CFO. Shareholders who so wish shall be afforded the opportunity to have contact with the MD, deputy MD or CFO. Such contact may take place by telephone, fax, e-mail, letter or personal visits. As regards ownership or board issues, the chair or a member specially appointed by her/him will respond.
Information submitted in the course of these contacts shall refer to previously publicized events and financial reports.
In conjunction with very special occasions, information that has not been publicized may be provided selectively; for example, in the event of a planned new issue, in connection with negotiations concerning a corporate acquisition or in the event of contacts with a rating institute. The recipient must always be made aware that this information is confidential and that the recipient thereby becomes an 'insider'. In conjunction with M&As, a logbook must be kept in accordance with the regulatory provisions.
Website
Cordovan Group's website on the Internet shall satisfy the formal requirements imposed by the Stockholm Stock Exchange, but should also contain such information as a company with international operations and high IR ambitions is expected to provide. An appointed 'webmaster' will act as the person responsible for practical aspects within the framework of the company's overall information/communications policy.
Policy concerning rumours and information leaks
The policy of the Cordovan Group is not to comment on rumours affecting the company or individual commercial events.
The company shall deal with sensitive information at all levels in such a way that minimizes the risk of 'leakage'. Annual and interim reports should be publicized as soon as possible to minimize the risk of information leaks.
The company will only opt to provide clarifying information when the spreading of rumours is considered to be harmful to our operation.
No more people than necessary will be involved in negotiations concerning corporate acquisitions or sales. Such individuals should sign a confidentiality undertaking and be informed that they are subject to the insider provisions.
When important corporate events are imminent, or if it may be assumed that they may occur, a press release, document or other statement shall be prepared in advance so that it can be quickly publicized if necessary.
The above Information/Communications Policy was approved by the board of Cordovan Group AB (publ) on 17 December 2007.
Officers holding posts referred to in the Information/Communications Policy
Rolf Jansson, CEO & President
Anders Gahnström, CFO
www.cordovangroup.com and www.cordovangroup.se are Cordovan's website for IR and media contacts.