FINANCIAL COMMUNICATION: FRAMEWORK AND PRACTICES - 2019 EDITION

14 1  z NOTIONS OF PERIODIC INFORMATION, ONGOING INFORMATION AND REGULATORY INFORMATION Financial information is subject to thorough and often complex regulations, which primarily distinguish between (i) “periodic information”, (ii) “ongoing information” and (iii) “regulatory information”, to which can be added (iv) specific transaction-related information. In October 2016, the AMF published an overview of the various information requirements that listed companies must fulfil (AMF Position/Recommendation no. 2016-08 – Guide to ongoing disclosures and the management of insider information, p. 3 and AMF Position/ Recommendation no. 2016-05 – Guide to periodic disclosures by companies listed on a regulated market, p. 3 1 ). “Mid-cap” issuers (i.e., compartment B and C issuers on Euronext and Euronext Growth) may refer (i) to the AMF Policy Handbook for Mid-Caps, published in November 2016, which outlines the main rules governing financial reporting and disclosures, and (ii) to the guide published by the AMF on October 23, 2017 for SMEs and mid-tier firms, which provides an overview of the main market regulations and their applicable corporate law. This practical guide, which is organised by topic and listed market, covers in particular the procedures and deadlines for publishing financial information, the type of information to disclose and corporate governance‑related rules 2 . PERIODIC INFORMATION Periodic information includes information provided by companies whose securities are admitted to trading on a regulated market in France or within the European Union, where they fall within the AMF’s jurisdiction, at regular intervals, annually and half-yearly on a mandatory basis and quarterly on a voluntary basis. Periodic information most notably includes the requirement to disclose an annual financial report and a half-yearly financial report under the conditions defined by the AMF General Regulations 3 as well as to file the issuer’s annual management report and appendices at the commercial court registry as specified by the French Commercial Code 4 ( Code de commerce ). On October 26, 2016, the AMF published a guide to periodic information published by listed companies on a regulated market 5 , the purpose of which is to present the main requirements for listed companies concerning the disclosure of periodic information and bring together in a single document the related positions and recommendations of the AMF and the European Securities and Market Association (“ESMA”). This guide was updated on March 6, 2019 to take account of the new requirements regarding periodic information, in particular relating to the non-financial performance statement, duty of care plan, anti-corruption measures, corporate governance report, as well as to clarify certain recommendations relating to results press releases, internal control and risk management. 1 – AMF Position/ Recommendation no. 2016-05, updated on March 6, 2019. 2 – “Concise overview of issuers’ main obligations – Guide for mid-tier firms/SMEs – Obligations concerning Euronext and Euronext Growth (formerly Alternext)”. 3 – Articles L. 451-1-2 et seq. of the French Monetary and Financial Code. 4 – Article L. 232-1 II of the French Commercial Code. 5 – AMF Position/ Recommendation no. 2016-05 – AMF Guide to periodic disclosures by companies listed on a regulated market.