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FW: Media, internet and external communications policy
To all
Diebold Election Systems employees,
It is
imperative that each of you review the following e-mail from our global
marketing and legal departments concerning the fair disclosure regulation. As
part of a $2 billion public company, it is critical that our actions as
Diebold Election Systems employees meet the requirements of such
regulations.
Thank you all for a terrific year, and I hope you
have a great holiday season.
Best
regards,
Mark Radke
Diebold Election Systems
#1 in
the election system industry
From Don Eagon, vice president, global
communications and investor relations; and Warren Dettinger, vice president and
general counsel:
Late in 2000,
the Securities and Exchange Commission
(SEC) published Regulation FD (fair
disclosure) to restrict selective disclosure of material information -- that is
news and other information that can affect the stock price -- by public
companies. The scrutiny that public companies are coming under in light of
Regulation FD makes it even more critical that we maintain Diebold’s policy
regarding speaking to the public via the media and
Internet.
This note is to remind
all associates that any and all day-to-day external company
communications are affected by Regulation FD and may fall under SEC scrutiny.
The content of any voice mail, posting on an Internet chat site, phone
conversation, e-mail or memo to any external party may be considered
material.
Therefore, all queries
from news reporters, financial analysts and research firms must be funneled
through Global Communications.
Also, discussion of Diebold (products, financial speculation, status of
internal programs, etc.) in Internet chat rooms is not permitted whether or not
a posting has been identified as coming from a Diebold associate. Diebold will pursue the
identities of any such violations that occur on message boards that it suspects
may be coming from associates. This helps protect associates and the
company from SEC regulations and other potential public liabilities.
Be particularly aware
when communicating to a customer, supplier or any other external party regarding
various corporate information. For example:
-
A
customer’s impact on Diebold’s current financial situation.
-
An
impending order that will help meet a sales goal.
-
An
ongoing project or business trip that has to be postponed or canceled for
budgetary reasons.
To protect
yourself and the company, do not communicate with the investment
community or the media by representing yourself as a Diebold associate or
spokesperson whether by phone, e-mail, an Internet chat room, or in person. If
you should receive any communication from a Diebold investor or a reporter,
please forward it to Global Communications.
If you have any questions or
concerns regarding Regulation FD and this corporate policy, don’t hesitate to
contact Global Communications [Comnet 221-3790; +1 (330) 490-3790] or Legal
[Comnet 221-4506; +1 (330) 490-4506].
Thank you
for all your efforts in this matter,
Don
Eagon
Warren
Dettinger