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Effective immediately do not comment to the press. This applies to the
black box situation as well as all other communication.
This information was sent out December 19 (see below). EVERYBODY MUST
FOLLOW THIS POLICY. THERE ARE TO BE NO EXCEPTIONS.
From: Internal Communications
Sent: Thursday, December 19, 2002 1:54 PM
To: DL-Diebold All
Subject: Media, internet and external communications policy
>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
Dieboldís policy regarding speaking to the public via the media and
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
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 customerís impact on Dieboldís 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
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, donít 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,