FINANCIAL COMMUNICATION: FRAMEWORK AND PRACTICES - 2019 EDITION

142 The study published in November 2015 on systems used by listed companies to communicate with their individual shareholders by the AMF includes a presentation of the financial communication frameworks and tools currently used as well as an overview of existing practices and the AMF’s best practice guidelines with regard to this area. With the same obligations and objectives as for relations with institutional investors, financial communication targeting individual shareholders must take into account their specific needs, such as separate information distribution channels, a greater need for information regarding the company’s business and strategic approach, and personalised dissemination tools. The AMF recommends 186 that specialist documents or headings on the issuer’s website (i) contain a clear link to the presentation of the related risk factors, (ii) explain the company’s strategy in a balanced, educational manner, particularly with regard to future challenges and how the company’s strategy will respond to these, and (iii) systematically refer back to their registration document (or annual financial report), with clear details of where it may be consulted and highlighting the risk factors contained therein. Depending on the nature of an issuer’s business, it may be wise to combine its financial communication with its institutional communication, for example, in the case of consumer goods and services. Additionally, any company that wishes to build and retain a significant individual shareholder base must also incorporate this strategy into its financial policy (for example, by offering interim dividends and splitting the shares to make them more accessible, etc.). Some associations represent the interests of individual shareholders or investment clubs. Certain associations aim to defend the rights of non-controlling interests, particularly in the case of financial transactions. Issuers may find it useful to engage in dialogue with these associations and meet with them when preparing their shareholders’ meetings, in order to better identify their expectations. Employee shareholders As is the case with communications for individual shareholders, communications aimed at informing employee shareholders must have an educational character. They are subject to the same legal obligations as those presented in Part 1, especially those concerning equal treatment. Several supporting tools may be used to communicate with employee shareholders, including in particular a dedicated employee shareholder intranet site, a specific letter or a “Shareholder” section in any in-house publications. The content may consist of strategy-related performance indicators, specific information concerning the employee shareholder base (percentage held, geographical breakdown, etc.), information about the share itself (earnings releases, events, comments on share price trends, dividends, etc.) and the various means by which it is held (through the employee stock-ownership programme, in pure registered, administered registered or bearer form, etc.). 186 – AMF Recommendation no. 2015-09 – Communication by companies aimed at promoting their securities to individual investors.