This Communications Policy set out the guideline for information dissemination within Linkage Assurance and how the representatives of Linkage shall communicate with external parties, particularly shareholders, the media, regulators, the government, and other stakeholders.
2. DEFINITION OF TERMS
For the purposes of this Policy, the following definitions apply.
a. “Authorized Spokesperson” means the Managing Director, Executive Director, the Company Secretary, Chief Financial Officer, Head of Corporate Affairs, or person(s) performing similar functions, or any other employee or representative, specifically authorized by the Managing Director to speak with a Third Party with respect to a particular topic or on a particular occasion.
b.”Confidential Information” is any information about the Company that has not been made publicly available, as well as information the Company is under a legal obligation to keep confidential.
c. “External Communication” is the dissemination of information to external stakeholders.
d. “Internal Communication” is the dissemination of information to, employees, Managers, Directors, and Internal stakeholders.
e. “Material Information” information is considered material, if there is a reasonable likelihood the information would influence the investor in making an investment decision regarding the purchase or sale of the Company’s shares.
f. “Publicly Disseminated” means that information has been made available by the Company to the public through a widely disseminated medium.
3. INTERNAL COMMUNICATIONS
Internal communications shall be carried out in acceptable language and must, directly or indirectly, convey any political, religious, or racial connotation. All reports, presentations, memos, emails, and official correspondences must conform to the approved font requirements.
Communication between and amongst Staff members must always be professional. Internal correspondences must be in line with the Company’s acceptable standard. Employee’s formal correspondence with a third party must be sent through the company’s approved electronic mail or documented on printed paper bearing the company’s letterhead with the consent of the head of the employee’s department initiating the correspondence. Correspondence with Government agencies, regulators, corporate entities, suppliers, distributors, social institutions etc. must be issued by a Head of Department.
Employees and Managers must maintain the confidentiality of the information with which they are entrusted. The only exception is when disclosure is authorized or legally mandated. Confidential information includes, among other things, any non-public information concerning the company and any non-public information provided by a third party with the expectation that the information will be kept confidential and used solely for the purpose for which it was conveyed. This includes information about clients or colleagues, as well as the company’s strategic and business plans.
Employees are not permitted to speak with any news media regarding commercial information about the company’s activities. All media enquires must be directed to the Head, Corporate Affairs, and the Managing Director.
Only the Managing Director and the Head of Human Resources are authorized to broadcast or authorize the broadcast of mass messaging to all employees.
4. EXTERNAL COMMUNICATIONS
All external communication must be approved by the Managing Director (MD/CEO). All communications with shareholders, investors, analysts, researchers, market regulators and other related stakeholders, must comply with applicable law.
All presentations/materials for external use must be reviewed by MD/CEO, the Company Secretary, and the Head of Corporate Affairs prior to exposing these documents to the stakeholders to ensure brand compliance and accuracy of information related to the Company. This includes presentations to external stakeholders at meetings, seminars, conferences, etc. and materials to be uploaded to the website.
Communication with media is to be handled with the highest levels of sensitivity and professionalism and must always be handled by the Head of Strategy and Head of Corporate Affairs. Only persons authorized by the MD/CEO can grant interview or speak with the media on any matter.
Investors and stakeholders should send enquiries to the company via [email protected] email. The MD/CEO, Head of Corporate Affairs and the Company Secretary have responsibility for responding to enquiries and all emails received on the portal are treated and responses sent within 24 hours.
Where necessary, the Company will organize formal engagement with the media or issue press releases to disclose information that is important or of use to the public.