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Survey Results: Regulation FD Practices


1. Our company has a written policy addressing Reg FD practices: (Total responses: n=59)
(select only one)
n=7 (11.86%) Yes, and it is publicly available on our website
n=37 (62.71%) Yes, but it is not publicly available on our website
n=8 (13.56%) No, but we are in the process of drafting such a policy
n=7 (11.86%) 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=55)
(select only one)
n=35 (63.64%) We do not allow private reaffirmations
n=6 (10.91%) Rule of thumb allowing for private reaffirmations of one week or less
n=6 (10.91%) Rule of thumb allowing for private reaffirmations of one to two weeks
n=3 (5.45%) Rule of thumb allowing for private reaffirmations of two weeks or longer
n=5 (9.09%) 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=58)
(select all that apply, may total more than 100%)
n=4 (6.90%) Are not permitted to meet privately with analysts
n=37 (63.79%) Are only permitted to meet privately with analysts so long as someone else accompanies them (such as general counsel or IR officer)
n=19 (32.76%) Are permitted to meet privately with analysts after briefing by IR officer, general counsel, etc.
n=15 (25.86%) Are only permitted to meet privately with analysts during certain designated times



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