Guiding Principles for External Communications

In order to safeguard clear, effective and timely communication of a company’s goals, strategy and decisions as well as issues related to their implementation, you should develop guiding principles for external communication by members of the Executive Board and senior management.

Take a look at the following guidelines issued by the European Central Bank. You might want to compare these guidelines with your current company’s guidelines:

Confidential – Potentially Financial Market Sensitive – Information

Accept speaking engagements at events where remarks could be seen as financially market-sensitive only a) if these remarks are published on the Company’s website at the start of the speech, or b) if the event can be monitored and followed directly by the general public (e.g. via a live webcast), or c) if the event is attended by media representatives who could report in real time.

Refrain from offering to any institution, company or person who could derive profit from such information, personal views about the state of the economy or the financial sector relevant to the future stance of monetary policy that have not already been expressed publicly.

Strive to ensure, in selecting their speaking engagements, that the acceptance of such invitations is not perceived as giving the organiser a prestige advantage over a competitor or allowing them to benefit financially from apparently exclusive contacts with the members of the Executive Board.

Non-Public Events, Bilateral Meetings

When considering invitations to speak at non-public events or to accept bilateral meetings, e.g. with bankers, industry representatives, or with special interest and advocacy groups, the members of the Executive Board will ensure that no financial market-sensitive information is divulged. As a matter of principle and where practical, a Company staff member should be present at bilateral meetings.

Quiet Period

The members of the Executive Board re-affirm their adherence to the quiet period principle, whereby speeches and public remarks, given in the seven days prior to each scheduled monetary policy meeting of the Governing Council, should not be such as to influence expectations about forthcoming monetary policy decisions.

Read here the European Central Bank Press Release: ECB publishes guiding principles for speeches and meetings, 6 October 2015.

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