Confirmed by the Board of Directors of Hafa Bathroom Group (HBG) on 23.04.2010.
Hafa Bathroom Group AB (HBG) is the parent company within a group of companies that is 100% owned by the private equity company Ratos, which is quoted on the Stock Exchange.
HBG is a Nordic market leader in bathroom fittings. The company designs, manufactures and sells a wide range of bathroom products with a focus on the Nordic market.
2 Basic principles
HBG shall submit correct, relevant and reliable information to all stakeholders. Before the owner's publication of interim reports, year-end reports or annual financial reports, no comments must be made regarding HBG's financial development.
3 Communications activity
The Company intends, by way of its communication activities, to:
- Provide information about important events, continuously providing information to the Board of Directors concerning the financial status of the Company.
- Create interest in the business and build confidence in it.
- Create the conditions for increased dialogue with the outside world.
- Get the company's own personnel involved and committed.
The Company's work on information/communication is subdivided into the following business areas:
- External information
- Relationships with the mass media
- In-house information
3.1 Tools for communication
The Company's tools for external communication and relations with the mass media can include:
- press releases
- annual financial reports
- the website
- printed information materials
- electronic presentation materials
- responses to questions by telephone, e-mail and fax
4 Target groups
The information shall be easily accessible to the target groups. The information shall create confidence in HBG, thereby increasing the value of the company.
The following target groups for HBG's distribution of information have been identified:
- Financial markets
- Supervisory authorities
- Existing and potential customers
- Existing and potential suppliers and partners
- Media and other opinion-formers
- Company personnel
- Board of directors
5 Organisational structure
The MD is ultimately responsible for the HBG Group's communications with the market, society and the media.
Only the MD and the Chairman of the Board of Directors will provide information about/make statements about all general issues concerning the company externally.
5.1 Division of responsibility - information management
- The Marketing Manager is responsible for the overall coordination of the Group's media relations and graphical profile.
- The Group Financial Controller and MD provide HBG's target groups with financial and other relevant information.
- The MD, Marketing Manager and Group Financial Controller write and distribute press releases and take responsibility for the compilation of annual financial reports.
- The Marketing Manager is responsible for maintaining and developing the Group's websites.
6 Managing share price sensitive information
Employees within HBG shall adhere to the in-house confidentiality requirements which have been drawn up to prevent the spread of any information not intended for the public domain which could influence the share price for the owner. Confidentiality agreements shall be drawn up for external consultants and collaborative partners who have access to information that is not intended for the public domain and which could influence the share price.
6.1 Managing information leaks
In the event of a leak, the Company shall always report the actual circumstances.
In the event of rumours, the Company shall be consistent and always apply the following: ”The Company has a policy of not commenting on rumours.”
Under no circumstances must the term ”no comment” be used - it could be interpreted as confirmation. If the rumour is harmful to the Company, the Company ought immediately to inform its owners and the Board of Directors, after which a clarification may be made in a press release.
Ahead of important decisions, the owners and Board must always be kept informed and basic information for a press release must be prepared.
6.2 Crisis management
In the event of crises and negative publicity, strategy will be determined by the MD and the management team. The Chairman of the Board and the owner's representative will be contacted for advice and the MD will convene a crisis management team. The management team will always be part of this. It ought always to be determined whether a potential "duty press office" should be established for the issue in question. In-house information ought to be issued immediately – the MD is responsible for this. Issues dealt with in this way ought always to be evaluated in-house once it has been concluded to enable emergency preparedness to be improved.
7.1 Press releases
- Only the MD or Chairman of the Board will ever be indicated as spokespersons in press releases.
Press releases will be published in Swedish. To facilitate matters for non-speakers of Swedish, the Company has a policy of having all press releases translated into the English language and published as soon as possible on the Company's website. Translated information is always furnished with a notice explaining that the information is a translation from the Swedish and is not aimed at anyone other than where Swedish Law is applicable.
7.2 Contact people
Only the MD for the parent company and the Chairman of the Board will communicate with the financial market and the media on behalf of the Group. Other employees and office-bearers within the Group who are contacted by investors, shareholders, analysts or the media must always refer these directly to the MD, without making further comment. Subsidiaries within the HBG Group will not communicate with the media without the prior consent of the MD.
7.3 The Group's websites
The Marketing Manager is responsible for all of the Group's public websites.
The Group has a website for the publication of information regarding financial information on the Internet in accordance with this policy. The Marketing Manager is responsible for ensuring that the website is kept updated and describes the Group's activities in a correct, current manner. Apart from press releases and reports, details about the members of the Board of Directors and contact information are published there.
Group subsidiaries have their own websites for communicating with their respective markets. Design, content and functionality adhere to the Group's website in consultation with the Marketing Manager.
8 Policy concerning Information leaks and crisis management
In general, information leaks are the result of carelessness and a lack of discipline.
At least once a year, leading office-bearers must make it clear to all employees who have access to information that is share price sensitive for the owner, how important it is not to distribute this information.
Not to inform more people than is necessary.
9 Policy concerning in-house information
To ensure that the Company achieves its objectives, it is important for staff members to be involved and committed.
Well functioning in-house information/communication is one of the cornerstones of ensuring knowledgeable, committed members of staff who are the face of the Company that is seen by the outside world. In-house information constitutes the foundation for business activities aimed at the outside world. Employees are the most important messengers of the company's profile and form the foundation on which confidence in the Company's activities is based.
All in-house information must take into consideration the fact that our owners are quoted on the Stock Exchange, which may imply limitations on the scope of in-house information. Neither is it possible for all information to be conveyed to all employees because of Stock Exchange rules and for competitive reasons.
9.1 Different types of in-house communication
Internal communications can be subdivided into:
- work communication: allowing everyday work to be taken care of,
- communication of news: the latest events that people ought to know about to enable them to undertake their duties,
- management communication: controlling the business (budgets, targets, long-term planning),
- change communication: positioned outside the normal flow of news, in the event of major changes,
- cultural communication: an invisible part of the in-house communications.
All of these types of communication shall be developed.
9.2 Objective for the Company's in-house information/communication
By developing in-house information/communication, the Company wishes to raise its employees' skills levels and give them the opportunity to submit their views on the business.
Good in-house communications improve the Company's opportunities for achieving its objectives. It is particularly important to increase communication right across the organisation and between the different units. Developing in-house communication is a process in which leading officials are important forerunners and examples. Visible leadership is a key term. However, it is always the duty of the individual employee personally and proactively to keep informed in order to be able to undertake his or her duties. On a quarterly basis, after our owners' reporting, physical information meetings with the staff will be held at head office; these will be supplemented with information in writing to the remaining part of the business. A functioning in-house information system:
- creates unity concerning objectives,
- provides employees with a general overview,
- produces better decision bases,
- provides participation in decision-making,
- creates motivation,
- facilitates delegation,
- contributes to personal development,
- raises levels of efficiency.