THE INFORMATION DISCLOSURE POLICY IN KDPW
I. Purpose of the Information Disclosure Policy
1. The purpose of the implementation of the Information Disclosure Policy in KDPW is to establish standards for the effective distribution of information and measures for communicating with KDPW shareholders and participants, as well as organisations representing these participants.
2. KDPW manages a transparent information disclosure policy in its use of traditional and modern communication technologies, in addition to rapid and secure communication tools.
3. KDPW shall take all necessary measures to ensure that the information it provides meets the highest standards for content, delivery and presentation.
II. Beneficiaries of the Information Disclosure Policy
The beneficiaries of the Information Disclosure Policy in KDPW are:
b) participants – entities that are participants, or members of the depository system, the exchange clearing house, the investor compensation scheme, or trade repository, which are managed by KDPW, as well as pension fund management companies or open-end pension funds,
c) organisations representing participants.
III. Terms and conditions for providing information and sending replies to shareholders and participants
1. Notifying participants about the content of regulations issued by KDPW and about amendments thereto, as well as about the contents of other rules governing the rights and obligations of participants, issued on the basis of those regulations, shall take place at least 2 weeks prior to their coming into force. In exceptional circumstances this period may be shortened, on condition that it continues to comply with regulations issued by KDPW and legal provisions in force. The rules are published on the KDPW website.
2. Providing information to shareholders takes place in accordance with the applicable provisions of the Commercial Companies Code. KDPW shareholders are ensured the same terms and conditions with respect to access to information.
3. Replies by KDPW to enquiries from participants relating to KDPW business activities shall be sent within a reasonable time period in accordance with the relevant legal provisions in force, in particular provisions restricting access to specific types of information.
IV. Media used for communication with shareholders and participants
1. KDPW communicates with its shareholders and participants using media adapted to the needs and expectations of specific information recipients. These media include in particular:
a) correspondence with participants,
b) notifications for participants,
c) meetings with participants,
d) general information, including: presentations, handbooks and films,
e) public pronouncements and official viewpoints of the Management Board,
f) presentations and addresses at national and international industry conferences,
g) the corporate website, which provides essential information on KDPW and its business activities, the articles of association and annual reports,
h) making available on the website contact templates and email addresses of employees, assigned to specific interested parties.
2. The content of documents and information published on the KDPW website shall be prepared and distributed with all due care and attention and in instances where any amendments become necessary, the update shall be performed with the shortest possible delay.
3. The English language version of a document or information published on the website shall be published there in the shortest possible time following the publication of the same document or notification in its Polish language version.
V. Establishment of the Information Disclosure Policy and its publication
1. The Information Disclosure Policy in KDPW shall be adopted by the KDPW Management Board.
2. The Information Disclosure Policy in KDPW shall be subject to periodic review with respect to its adequacy and compliance with legal provisions in force, other regulations applicable to KDPW and internal regulatory measures.
3. The Information Disclosure Policy in KDPW shall be published on the KDPW website.