HR Regulation FD Policy

HR REGULATION FD POLICY

Policy Administration

Policy Owner:    Effective Date:

Approved By:

Purpose

The purpose of this Regulation FD Policy is to ensure that all material nonpublic information that may affect the Company’s securities is disclosed to the public in a manner that prevents selective or disparate disclosure. This policy establishes internal controls, authorized spokespersons, pre-disclosure clearance procedures, reporting obligations, and disciplinary measures to comply with applicable securities laws and to protect the Company and its stakeholders.

Scope

This policy applies to all directors, officers, employees, contractors, and temporary staff of the Company and its subsidiaries. Individuals in the following categories have specific obligations and must adhere to the procedures herein:

Covered Groups Executive Officers
Investor Relations
Finance and Accounting
Human Resources
All Employees

Definitions

Material Nonpublic Information: Information is material if a reasonable investor would consider it important in making an investment decision or if it would reasonably be expected to affect the market price of the Company’s securities. Information is nonpublic until it has been broadly disseminated and a sufficient period has elapsed for the market to absorb it.

Selective Disclosure: Communicating material nonpublic information to selected individuals or entities (for example, analysts, institutional investors, or media) without a simultaneous public release.

Authorized Spokespersons

Only designated persons may speak publicly on behalf of the Company concerning financial results, guidance, material events, strategic initiatives, or other matters that could be material to investors. Designated spokespersons are listed below and must receive pre-clearance for material disclosures.

Permitted Disclosures and Public Communications

Material information must be disclosed through recognized public channels concurrently or in advance of any selective discussion. Permitted disclosures that are not material include routine administrative information, general historical information, and information already available in public filings. All forward-looking statements must be clearly identified and accompanied by appropriate cautionary language when required.

Pre-Disclosure Clearance Procedure

Before any disclosure that could reasonably be considered material, the authorized spokesperson must obtain clearance from the Chief Legal Officer or the General Counsel and the Chief Financial Officer. Clearance requires written confirmation from each reviewer and documentation retained in the Company’s disclosure records.

Handling Analyst and Investor Inquiries

All inquiries from securities analysts, institutional investors, and the media must be referred to Investor Relations or an authorized spokesperson. If material nonpublic information is inadvertently disclosed, the authorized spokesperson must promptly consult with Legal to determine the need for public disclosure to cure the selective disclosure.

Social Media and Electronic Communications

Employees must not disclose material nonpublic information on social media or through electronic communications. Personal social media accounts must not be used to disclose Company material information. Any employee communications that may implicate public disclosure obligations must be cleared in advance with Legal and Investor Relations.

I acknowledge that I have read and will adhere to the social media rules contained in this policy: I acknowledge

Confidentiality and Material Information Controls

Persons with access to potential material nonpublic information must handle such information on a strictly need-to-know basis, maintain confidentiality, and use secure methods for storage and transmission. Disclosure to consultants or third parties requires a written confidentiality agreement and pre-clearance from Legal.

Reporting Violations and Whistleblower Protections

Employees must report suspected violations of this policy to the Chief Legal Officer, the Chief Compliance Officer, or through established whistleblower channels. The Company will not retaliate against employees who report concerns in good faith. False or malicious reports made with knowledge of falsity may subject the reporter to disciplinary action.

Training and Records

The Company will provide periodic training on Regulation FD obligations to all covered personnel and will retain records of clearances, disclosures, training attendance, and related documentation for a period consistent with Company records retention policies.

Disciplinary Action

Violations of this policy may result in disciplinary action up to and including termination, reimbursement of any ill-gotten gains, civil liability, and referral for criminal prosecution where appropriate. Discipline will be applied in a manner consistent with applicable employment laws and Company policies.

Employee Acknowledgement and Personal Information

By signing below, the employee acknowledges receipt of this policy, affirms understanding of the rules and procedures governing disclosure of material nonpublic information, agrees to comply with the policy, and consents to the Company’s procedures for clearance, record retention, and, where applicable, background checks.

Employment History (Most Recent)

Employment History (Prior)

Education

References

Legal Notices and Disclosures

At-Will Employment: Nothing in this policy alters the at-will employment relationship, unless otherwise provided in a signed written agreement between the employee and the Company.

Equal Opportunity: The Company is an equal opportunity employer. This policy will be enforced without regard to protected characteristics under applicable law.

I acknowledge that I have read and understand the above notices: I acknowledge

Certification and Authorization

I certify that all information provided on this form is true, correct, and complete to the best of my knowledge. I authorize the Company to contact my prior employers and references to verify my employment history and other information relevant to my responsibilities under this policy. I consent to any background and reference checks required by the Company as a condition of my continued employment or assignment of duties that involve access to material nonpublic information.

I further acknowledge that failure to comply with this Regulation FD Policy may result in disciplinary measures up to and including termination.

I consent to background and reference checks I authorize contact of prior employers

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