FINANCIAL COMMUNICATION: FRAMEWORK AND PRACTICES - 2019 EDITION

159 Regulations. In the opinion of the AMF, social media is an additional channel for market information but cannot be the only or main channel of such information. In addition to taking into account the AMF’s recommendations, issuers should also take care to ensure that employees are informed of the risks involved in disclosing information about their company via social networks. 4  z PROVIDING MANAGEMENTWITH FEEDBACK ON MARKET PERCEPTIONS “Market sentiment” includes investors’ and analysts’ perception of the strategy, activities, performance and outlook of the company and of the credibility of its management. Investor Relations officers play a key role in reporting market sentiment upwards to executives. The challenge lies in recognising when analysts’ and investors’ individual opinions become a general, shared impression – through conversations, roadshows, emails, the publication of sector notes, etc. – which it shares with the company’s executive management, or even the board of directors or supervisory board. Investor Relations officers must decide when and how to provide this information, which may depend on the topics and recipients concerned. DISSEMINATION OF ANALYST RESEARCH Investor Relations officers provide the company’s executives and occasionally its board of directors or supervisory board with full copies of the most relevant research (and summaries of all other research). It should be noted that recent case law of the French Conseil d’Etat concluded that certain work and estimations provided by recognised analysts and researchers may, in some instances, constitute insider information 198 . MONITORING OF MARKET CONSENSUS The consensus is the arithmetic average of sell-side financial analysts’ forecasts in relation to the key indicators (sales, operating income or EBIT, net income, earnings per share, etc.) of listed companies. In order for market consensus to be representative, it must incorporate the estimates of all of the analysts that actively monitor the shares. The median of the same indicators may also be provided. 198 – CE, January 30, 2019, no. 412789: penalty imposed on an analyst having used information based on a recommendation, not prior to publication but prior to distribution to a restricted circle.

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