Disclosure policy | Bangla | Download | Policy No 37
Compliance Bangladesh . Com (Company Name) must protect its confidential and proprietary information from Unauthorized disclosure. At the same time, the company has an obligation to ensure that its public communications are consistent, accurate and in compliance. This policy is therefore intended to guide company Managing Directors, Directors Officers and Employees in their handling of company information and, in particular, balancing the demands of confidentiality with the requirements of disclosure.
General Obligations:
Directors, officers and employees must not use for their personal gain or disclose (without proper authorization) to a third party any confidential or proprietary information concerning the company or its customers or suppliers obtained as a result of their employment with or representation of the company. Similarly, Directors, officers and employees should take appropriate precautions to avoid unintended disclosure of such information.
For example, you should not discuss company affairs in public or quasi-public areas where conversations may be overheard, and you should use appropriate care when transmitting company information over unsecure networks, such as the Internet. Directors, officers and employees may disclose to third parties confidential or proprietary information concerning the company or its customers or suppliers obtained as a result of their
Employment with or representation of the company, if such disclosure is within the scope of their employment with or representation of the company and the disclosure is authorized. For example, you may discuss confidential company information with an outside attorney representing the company in a lawsuit or, subject to a confidentiality agreement reviewed by the Legal Department, share proprietary company information with a technology partner.
Company personnel should note that their obligations under this policy coexist with–and do not supersede or modify–other confidentiality obligations they may have to the company (under, for example, an Employment Confidentiality And Intellectual Property Agreement) and to third parties with whom the company does business (under, for example, a confidentiality agreement).
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Communications with Stockholders and Securities Industry Professionals: disclosure policy | Compliance Bangladesh
The company is committed to fair disclosure of material information to its
Stockholders and securities industry professionals (such as securities analysts,
Investment bankers and mutual fund representatives) and avoiding selective disclosures of material, non-public information which may advantage certain market participants over others. Authorized disclosures to the public of material, non-public information will therefore be made through the Corporate Relations Department or Investor Relations
Department, and will initially occur in a widely-distributed press release or, following consultation with the Legal Department, by another method reasonably expected to effect a broad and non-exclusionary public distribution of the information.
In addition, the company will make accommodations for widely-accessible,
Real-time broadcasts of the company’s participation in industry conferences, analyst meetings and conference calls, and other “live” public
Communications at which company representatives may be expected to address material, non-public information.
The company will widely publicize how to access such broadcast at least two days in advance using the procedures described in this policy.
Similarly, direct communications with stockholders and securities industry professionals must avoid disclosure of material, non-public information or be widely broadcast in real time as described in this policy. As a result, direct communications with stockholders and securities industry professionals regarding the company may be conducted only by the following company Owner permission or instruction.
Stockholders and securities industry professionals regarding the company–for example, as part of a company presentation to analysts–at the direction of an authorized officer or employee. In general, however, directors and other officers and employees should refrain from any direct communications with stockholders or securities industry professionals regarding the company, and instead direct those communications to the company’s Director, Investor Relations.
For purposes of this policy, material information will be considered “non-public” until it has been disclosed in a broad and non-exclusionary public distribution. Also, information is generally considered “material” if a reasonable investor would consider it important in making an investment decision regarding the company’s securities. You should assume that information regarding the following topics is “material” for purposes of this policy:
- Earnings, revenues and other financial information;
- Significant mergers, acquisitions and joint ventures;
- Significant new products and technologies,
- Significant developments regarding customers and suppliers; and
- Dividends, stock splits and other important events regarding the company’s securities.
If you are uncertain as to whether a particular item of company information should be considered “material,” contact the Store Department.
disclosure policy | Compliance Bangladesh
Unauthorized Disclosures:
Directors, officers and employees should immediately contact the Legal
Department if they become aware of any potentially unauthorized or inadvertent disclosure of confidential company information. If the disclosed information is material and disclosure has been limited to certain stockholders or securities industry professionals, then the company will immediately take appropriate remedial actions to effect a broad and non-exclusionary public distribution of the information as described in this policy.
Communications with the Compliance Bangladesh (Company Name) Board of Directors:
The company and its Board of Directors believes that stockholders should have the right to communicate directly with the Board. As provided elsewhere in this policy, directors should refrain from any direct communications with stockholders or securities industry professionals regarding the company, and instead direct those communications to the company’s Country Director.
disclosure policy | Compliance Bangladesh
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