Communication and Disclosure Policy

This policy document covers Alma Media communications, disclosures and investor relations.

A. Communication policy

Alma Media Corporation is a company listed in the NASDAQ OMX Helsinki Stock Exchange. This policy statement defines the principles, roles and responsibilities of Alma Media’s communication and investor relations within the Group.

a) Objectives and publicity principle

At Alma Media, the tasks of communication are
- to fulfil the communication obligations of a listed company
- to manage the reputation of Alma Media
- to support the business operations and strategy of the Group through communication activities

Alma Media’s publicity principles are based on openness and transparency while observing the regulations pertaining to listed companies.

b) Communication organisation

Alma Media’s communication is organised into Corporate Communications under the parent company, as well as a communication network comprised of the persons appointed responsible for communication at the Group’s business units and operational chains. Corporate Communications is headed by the Vice President Communications and Investor Relations.

c) Practice and procedures in communication situations

Alma Media Corporation makes every effort to communicate in an equal manner in all situations, that is, to give the same information to all stakeholders at the same time. The communication threshold is the same for both positive and negative matters.

The financial status of Alma Media is commented upon by the President and CEO, the Chief Financial Officer (CFO) and the Vice President, Communications & IR.

The company will not comment on competitors, individual activities of competitors, matters related to the company’s owners or ownership, the level of its share price nor market rumours even on request.

Alma Media employs internal Insider Guidelines to complement the regulations regarding the management and handling of insider information stipulated by law, the standards of the Financial Supervisory Authority and the insider regulations of NASDAQ OMX Helsinki Oy. Alma Media educates and informs its insiders to understand their position and its importance.

All stock exchange releases and press releases are archived on the company’s public website.

B. Disclosure policy

a) Disclosure obligation

The financial communication for Alma Media Corporation is the responsibility of the CFO. The practical activities and the coordination of financial communication are concentrated in Corporate Communications.

The company’s CFO, General Counsel and Vice President Communications & IR are together responsible for all aspects of the company’s financial communication meeting the requirements of the Securities Markets Act, the regulations by the Helsinki Stock Exchange and the supervisory authorities. Alma Media also observes other recommendations for the communications of listed companies, for example related to its corporate governance.

According to the Securities Markets Act, the issuer of a security subject to public trading shall, without undue delay, disclose and file with the party in charge of the public trading in question all its decisions as well as all information on the issuer and its activities that are likely to have a material effect on the value of the security.

At Alma Media, matters stipulated by law, on which a stock exchange release must be issued, include:

(1) financial statements and interim reports covered by the obligation of regular disclosure
(2) changes in performance management
(3) correction of incorrect information
(4) changes in shareholding (flagging notices)
(5) future outlook
(6) deviations from earlier publicised information
(7) death, serious injury or illness of the members of the Board of Directors, the Group Executive Team and the heads of large business units (more than 10% of consolidated sales)
(8) substantial loss or damage

In addition, stock exchange releases are issued on all appointments in the Group Executive Team as well as other appointments that may have an effect on the image of the company as an investment. Such appointments include, for example, appointments for the positions of Editor-in-Chief for national and regional newspapers, and for Managing Director of subsidiary companies.

A stock exchange release is issued on all acquisitions, investments and divestments that are strategic or have a significant value.

b) Languages

Stock exchange releases, press releases and financial reviews are published simultaneously in Finnish and English.

c) Disclosure of future outlook

Alma Media publishes its statements about its future outlook in the interim reports and the financial statements release.

The guidelines are changed if the company receives information on the development of its net sales or financial result that deviates from earlier guidelines. Such changes are published separately and without delay.

According to Alma Media’s disclosure policy, a change of +/- 5% in the expected full-year operating profit without one-time items or future outlook may have a material effect on the value of its share. This is why a change exceeding the 5% limit in the metric followed will result in a change in performance management and thus publishing information on the change of the guidelines.

C. Investor Relations

At Alma Media, the release of information to shareholders, investors and analysts is coordinated by Corporate Communications, which is also responsible for organising investor events.

In connection with publishing its financial results, Alma Media always organises a conference for analysts and the press at which members of the Group Executive Team are present. These events are also open to investors. In addition, an English-language webcast is arranged for foreign investors and analysts.

The company strives to regularly meet investors outside Finland after the publication of interim reports. Participants in these roadshow trips, organised mainly by brokers, are appointed on the principle of both purposefulness and equality.

The meetings between the management and institutional investors and analysts are coordinated by Corporate Communications. The objective is that a person representing the IR function is always present at the meetings (VP Communications and IR, CFO or Communications Manager).

The company makes an effort to organise an annual Capital Markets Day targeting institutional investors.

Alma Media participates in selected events for private investors in Finland. These include investment fairs, stock exchange evenings and events by private investor associations.

A three-week silent period is observed in investor relations. These periods are published on the company’s web pages under the heading Investors’ Calendar.

Page last updated 24.10.2011