Notice No. 20210611-28
Notice Date 11 Jun 2021
Category Circulars Listed Companies
Subject : Guidance note on communications by Listed Entities
Company Secretary / Compliance Officer
Dear Sir \Madam
One of the mediums being used by listed entities to communicate with their stakeholders is the Exchange platform provided in the form of its website. Apart from regulatory filings, entities provide updates on their performance, awards/recognition received worldwide, positioning themselves as a leader, etc. There are also instances wherein Key Managerial Personnel or any other person representing the listed entity is seen disclosing the company’s prospects, future plans, etc while being interviewed. While all this may be significant to survive in an ecosystem in which the company operates, stakeholder interest is of paramount importance as well. The company shall ensure that no price-sensitive information is disclosed unless the same has been first disclosed to the stock exchanges.
The below is an indicative list of things that shall be kept in mind by the listed entities while publicizing the company:
a. The statement made shall be truthful, fair, evidence-based and shall not be manipulative or deceptive or distorted and the listed entity shall not make any statement, promise, or forecast which is untrue or misleading.
b. The information shall contain clear, concise, and understandable language.
c. If the listed entity presents any financial data, data for the past three years shall also be included along with particulars relating to sales, gross profit, net profit, share capital, reserves, earnings per share, dividends, debts, and the book values. The companies should also provide a link to the company’s website where the details are available and can be verified.
d. Listed entities shall use simple and easy-to-understand language without using extensive technical, legal terminology, or complex language. The details provided should be adequate and appropriate so that the investors are not distracted with excessive details.
e. The company should provide information only with respect to publicly reported financial information and not provide any forward-looking statement.
f. Non-factual and unsubstantiated statements shall not be made.
g.The company can position itself as a leader, pioneer, expert, or any word indicating it as the best only based on factual data which is widely available and not based on single-source, unless such source is a recognized source and has third-party certification. The company shall also indicate the source based on which such claim is being made and the information on such source should be in the public domain and verifiable.
h. In case of receipt of awards/recognition, disclosure shall include whether the listed entity has any relations with the awarding agency along with the number of participants that were evaluated, recognition of the awarding agency in the field in which award is given, and publicly available information relating to the awarding agency.
While the above is just an indicative list, listed entities shall be guided with the intention of the guidance note to protect the interest of the stakeholders.
Dy. General Manager
June 11, 2021