NKT A/S is a listed company, and as such is obliged to comply with regulations issued by Nasdaq Copenhagen concerning the publication of information which might affect the price of the share. These regulations are not 100% unambiguous, and listed companies are expected to make their own decisions in each case as to whether the information published is subject to the ethical regulations of Nasdaq Copenhagen which state that any information that might affect the price of shares must be made available to all investors at the same time.
In order to ensure compliance with the above regulations, Nasdaq Copenhagen recommends that listed companies implement a written Investor Relation policy.
Group management of NKT has supreme responsibility of the day-to-day Investor Relation activities, and is thus responsible for ensuring that the NKT A/S at all times complies with Nasdaq Copenhagen regulations.
Accordingly, companies owned directly or indirectly at least 50% by NKT must contact a member of Group management at NKT A/S in each case before communicating with shareholder related stakeholders of NKT:
- Stock analysts
- Non-employee shareholders
- Portfolio managers
- Members of the financial media
Communication of price sensitive information is in all circumstances limited to members of Group management.
3.1 Reference to other group policies
Reference is made to the Group policies for:
- Insider knowledge and trading
4.1 Mission statement for Investor Relation activities
It is the company's aim to maintain a high and consistent level of information and to be proactive and open in its communication with shareholder related stakeholders within the boundaries of current stock exchange regulations.
NKT strives - by use of its information and Investor Relation policies - to ensure the availability of relevant and updated information for valuation of the share price, and that the company is in compliance with prevailing stock exchange regulations.
4.2 Investor Relation responsible
Group management is responsible for Investor Relation activities. The operational responsibility is anchored with the CFO of NKT. Communication with private investors is delegated to the communications department.
4.3 Disclosure of price sensitive information
Material and price sensitive information must always first be disclosed to Nasdaq Copenhagen by electronic transmission of information through the GlobeNewswire system. Upon written acknowledgement of completed transmission by Nasdaq Copenhagen, the information may be distributed to other media (e.g. press, analysts, shareholders, homepage, etc).
Price sensitive information must be disclosed without delay, and - if possible - during opening hours of Nasdaq Copenhagen.
It's the responsibility of Group management that all price sensitive information is disclosed in a timely manner to Nasdaq Copenhagen. When in doubt, Group management determines whether information is price sensitive - eventually after consulting Nasdaq Copenhagen.
4.4 Preparation of company announcements
Company announcements must be prepared in an unambiguous fashion, in order to ensure that the market at first understands the content. The Group Chief Executive or the Chairman of the Board of Directors must approve all company announcements.
4.5 Interaction with stock analysts, shareholders and investors
Members of Group management participate on a regular basis in capital market days, one-on-one meetings, telephone conferences and presentations involving stock analysts, shareholders, investors, etc. The purpose of these activities is to elaborate over information previously disclosed, and to provide an opportunity for shareholder related stakeholders to interact with group management in Q&A sessions.
Information provided at such occasions must not be price sensitive. Thus, earnings expectations must only be discussed if disclosed in advance via Nasdaq Copenhagen.
As a tradition, stock analysts, investors and the press are invited to an NKT-hosted presentation following disclosure of quarterly and full-year results. A live webcast with the accompanying presentation are available to the public on the NKT homepage, as are the audiocasts on demand for a period of time following the session. The accompanying presentation is available on the website for at least two years.
All information disclosed to Nasdaq Copenhagen must afterwards be made available via the NKT homepage (www.nkt.com) without delay. All announcements (except for standard announcements) are sent via the NKT website mailing facility to subscribers of NKT’s electronic news service.
It's NKT’s ambition to create and maintain a homepage among the best (Top-20 of the listed companies in Denmark) with regard to investor relation activities.
4.7 Analyst reports
To ensure as accurate a picture of NKT as possible, we encourage analysts to forward drafts of their reports to a member of Group management for feedback and comments. To comply with Nasdaq Copenhagen regulations, our policy for these activities is:
- To make sure, that reports adequately reflects previously disclosed information
- Only to comment on previously disclosed information
- Never to comment on consolidated earnings expectations for current year and consolidated analyst projections for future years
- Never try to persuade an analyst to change his/her investment rating
It's against our policy to distribute analyst reports to third parties. Instead we publish a list with the analysts following NKT on our homepage, thus facilitating third parties to contact the analysts directly.
4.8 Silence period
It is our policy:
- Not to comment on wording or factual information in analyst reports less than 3 weeks before a planned release of earnings results (quarterly, half-year or full-year)
- Not to participate in meetings or presentations with analysts or investors less than 3 weeks before a planned release of earnings results
- Not to discuss financial matters with analysts or investors less than 3 weeks before a planned release of earnings results
5. Allocation of responsibility
The management of NKT A/S will update this policy as needed
The managing director of each Group company is responsible within the company for ensuring that the policy and guidelines lead to practical action, and must subsequently check that the guidelines have been complied with.