This disclosure policy embraces regulatory compliance obligations and encompasses the spirit of transparency and fairness. It will communicate internally to ensure that it is well understood and consistently applied by all senior management participants, and regularly communicated to employees and outside world.
Material information consists of both material facts and material changes relating to the Company’s business and affairs. Examples of some developments that could result in material information are as follows:
- acquisitions and dispositions;
- major reorganizations, amalgamations, or mergers;
- developments that affect the company’s resources, technology, products or markets;
- a significant change in capital investment plans or corporate objectives;
- major labour disputes or disputes with major contractors or suppliers;
- significant new contracts, products, patents, or services or significant losses of contracts or business;
- senior management changes;
- legal proceedings or regulatory matters; changes in financial results or credit arrangements; or
- changes in corporate structure or capital structure.
To prevent the misuse or inadvertent disclosure of material information, the following procedures should be observed at all times:
- Documents and files containing confidential information should be kept in a safe place, with access restricted to individuals who ‘need to know’ that information in the necessary course of business. Code names should be used if necessary.
- Confidential matters should not be discussed in places where the discussion might be overheard, such as elevators, hallways, restaurants, airplanes or taxis.
- Confidential matters should not be discussed on unsecure cell phones.
- Confidential documents should not be read or displayed in public places and should not be discarded where others can retrieve them.
- Employees must ensure they maintain the confidentiality of information in their possession outside of the office as well as inside the office.