Statement of Disclosure Policy & Practices
ATCO Ltd. (“the Corporation”) is committed to providing accurate timely information and fair disclosure of corporate information to the public. The Corporation must comply with all laws and regulations and ensure that communications to the public are disseminated according to applicable legal and regulatory requirements. The Corporation is committed to conducting business at the highest legal and ethical standards.
This policy applies to all directors, officers, employees, contractors and consultants of the Corporation.
The purpose of the Disclosure Policy is to:
- set clear guidelines for our people on disclosure requirements and practices;
- ensure that information which may be material in nature is accumulated and communicated to senior management of the Corporation, including the Chair, President & Chief Executive Officer (Chair & CEO) and the Senior Vice President & Chief Financial Officer (CFO), to allow timely decisions on required disclosure;
- ensure that public disclosure made by the Corporation does not contain a “misrepresentation” (a misrepresentation is defined by securities legislation as an untrue statement of material fact or an omission to state a material fact that is required or necessary to be stated to make a statement not misleading);
- provide a framework for determining materiality in the Corporation’s public disclosure guidelines, considering both quantitative and qualitative factors;
- provide guidance on dissemination of corporate information to share owners and the public;
- ensure that communications to the investing public are timely, factual and accurate; and
- ensure compliance with legal and regulatory requirements on disclosure.
Coverage and Application
The Disclosure Policy covers written and oral communications provided to the investing public, including:
- written financial and non-financial documents; Annual Reports, Interim Reports, news releases, letters to share owners, presentations and speeches by senior management, corporate web sites and other electronic communications and disclosure in documents filed within securities regulators and the Toronto Stock Exchange; and
- oral statements made in individual or group meetings, telephone conversations with financial analysts and the public, interviews with the media and news conferences.
Material Information and Disclosure
Material information is any information that a reasonable investor would consider important in making an investment decision regarding the purchase or sale of ATCO's securities, or would reasonably be expected to affect the market price or value of those securities.
The Corporation will adhere to the following disclosure principles when disseminating material information to the public:
- Dissemination of information will be factual and balanced, neither overemphasizing favourable news nor under-emphasizing unfavourable news.
- There will be no selective disclosure. Previously undisclosed material information will not be disclosed to selected individuals. If previously undisclosed material information is inadvertently disclosed, this information will be broadly disclosed immediately via news release.
- Disclosure will be corrected immediately if the Corporation subsequently learns that earlier disclosure contained a material error at the time it was given.
To minimize the potential of a misrepresentation being made, the Corporation has designated a limited number of spokespersons responsible for communication with the investment community, regulators or the media.
The Corporation’s designated spokespersons are:
- the Chair of the Corporation
- the CEO of the Corporation
- the CFO of the Corporation
- Managing Directors (or equivalent) for their respective subsidiaries
- the senior operational leaders of our business
Communicating with Market Professionals
The Corporation will not disclose significant data, and in particular financial information such as sales and profit figures, to financial analysts, institutional investors, and other market professionals selectively rather than to the market as a whole.
The Corporation does not comment on financial analysts’ reports. Financial analysts’ reports are proprietary products of the financial analysts and will not be distributed outside the Corporation, or posted on the Corporation’s website. Financial analysts’ recommendations or opinions will not be referred to in external communications or presentations.
Communicating with the Media
The Corporation will not provide material information to the media on an exclusive or selective basis but may work directly with selective media to profile non-material information.
Responding to Market Rumours
The Corporation will not comment, affirmatively or negatively, on market rumours.
The Corporation does not provide earnings guidance or forward-looking information other than specific information required by regulation.
Any information which is placed on ATCO's websites is strictly controlled and continuously monitored, to ensure that disseminated information is consistent, accurate an current.