Survey Results: Regulation FD Practices

1. Our company has a written policy addressing Reg FD practices:(Total responses: n=74)
(select only one)
n=6 (8.11%) Yes, and it is publicly available on our website
n=47 (63.51%) Yes, but it is not publicly available on our website
n=9 (12.16%) No, but we are in the process of drafting such a policy
n=12 (16.22%) No, and we do not intend to adopt such a policy in the near future

2. Regarding reaffirmation of earning announcements, our company uses one of the following rules of thumb regarding private reaffirmations:(Total responses: n=71)
(select only one)
n=51 (71.83%) We do not allow private reaffirmations
n=5 (7.04%) Rule of thumb allowing for private reaffirmations of one week or less
n=3 (4.23%) Rule of thumb allowing for private reaffirmations of one to two weeks
n=4 (5.63%) Rule of thumb allowing for private reaffirmations of two weeks or longer
n=8 (11.27%) We permit private reaffirmations - but never use a rule of thumb, instead we require confirmation of no material change with CEO, GC, etc.

3. At our company, our CEO and other senior managers:(Total responses: n=72)
(select all that apply, may total more than 100%)
n=5 (6.94%) Are not permitted to meet privately with analysts
n=30 (41.67%) Are only permitted to meet privately with analysts so long as someone else accompanies them (such as general counsel or IR officer)
n=35 (48.61%) Are permitted to meet privately with analysts after briefing by IR officer, general counsel, etc.
n=22 (30.56%) Are only permitted to meet privately with analysts during certain designated times