FINANCIAL COMMUNICATION: FRAMEWORK AND PRACTICES - 2019 EDITION

18 Assuming that an issuer or any of its subsidiaries are listed in a foreign country, the information must be disseminated simultaneously in France and the foreign country . It should be noted that the principle must be applied both for the dissemination by a press release and for the notification or the filing of documentation with foreign authorities (for example, the 6K report in the USA). Issuers are also recommended to disclose financial information outside of market trading hours in order to permit all investors to assimilate the information before the beginning of trading to avoid turbulent changes in the issuer’s share price. In that respect, even if the French legal transposition of the directive on financial instruments markets (the MiFID ) put an end to the requirement to concentrate market transactions on the regulated markets and welcomed alternative means of executing transactions, the majority of share transactions for French issuers listed on Euronext Paris remains on Euronext Paris. Under those conditions, the opening and closing hours for trading securities on Euronext Paris will continue to provide the appropriate reference for the publication of information by companies listed on Euronext Paris. In the case of a multi-listing, it is recommended that issuers adapt their dissemination procedures to avoid disclosing significant new events while the market is still open. The standard practice for French companies is nevertheless to base themselves on the trading hours of Euronext Paris. They do however retain the right to use another stock exchange’s hours as a reference. Finally, in order to respect the principle of equal access to information for all shareholders, in the case that an issuer holds a significant stake in another listed company, it is essential that the communication calendars of the issuer and that company are coordinated. 3  z PRINCIPLE OF CONSISTENCY According to the principle of consistency, the communication of information must be considered by the issuer in light of prior communication practices in order to avoid misleading investors. Specifically, the issuer must maintain the same treatment regarding the communication of information likely to impact its share price either upwards or downwards. In applying the principle of consistency, the issuer must also ensure the coherence of all information disseminated, regardless of the date, format or recipient of the information. In particular, financial information disseminated through the written press must be consistent with information disseminated by electronic means. This requirement for consistency implies the implementation by the issuer of a pre-dissemination control process and the centralisation of information disseminated.