The Company encourages participation by its employees in industry forums as well as civic, community, and political affairs. However, various legal and regulatory restrictions may be applicable to both the content and the timing of any public positions taken by employees. Prior to accepting any invitation to speak, submit articles or papers, or to give other presentations in any public forum, an employee must first receive approval from his or her direct supervisor. The supervisor, in turn, must seek written approval from the General Counsel who will ensure the proposed subject matter and timing is appropriate. Drafts of proposed speeches, articles and other presentations must be submitted to the General Counsel for approval before submittal or use. These materials must be submitted for approval at least two weeks prior to the submittal deadline, or the actual presentation date, whichever comes first.
All proposed press releases, advertisements, submittals of Company information to third party publications and other materials which may be printed or otherwise attributable to the Company are to be submitted to the General Counsel and the director of investor relations before release. These individuals will ensure that other necessary internal approvals have been obtained, and these are the only employees of the Company authorized to release such materials for publication.
Any inquiry to the Company from trade publications, newspapers, radio and television or other media, financial analysts and current or potential investors, must be referred to the director of investor relations for response.