Authorized Spokespersons
Investment Community — The following individuals are authorized to communicate with the investment community (including analysts, stockbrokers, individual and institutional shareholders but excluding the media and rating agencies):
For purposes of these Guidelines, these individuals are referred to as “Authorized Investment Community Contacts.”
End of Quarter Communications and Meetings
1. Quiet Period —The period beginning two weeks prior to the end of the quarter and ending at the time of the earnings release for that quarter should be observed as a quiet period with no general business discussions with analysts and investors. Exceptions may occur at the company’s discretion based on need to discuss breaking news.
2. Analyst Meetings/Conference Calls — All analyst meetings/conference calls to discuss quarterly and annual financial and business information should be simultaneously broadcast over the internet or via telephone conference call to all interested members of the public. Appropriate advance notice of the meeting, and the simultaneous broadcast, should be made in a press release or other method of communication in compliance with Regulation FD.
3. Earnings Press Release — Earnings Press Release will be released to PR Newswire and posted on the Corporate Website at or prior to the commencement of meeting/call as determined by Investor Relations and the Chief Financial Officer.
4. Guidance, relative to the First Call EPS range for the year, will be provided at each quarter.
Communications with Analysts
1. Review of Analyst Draft Reports — When asked to review analyst draft reports, the Investor Relations Department should limit review and comment to the following:
(a) Correcting historical factual information only.
(b) Pointing out information that is in the public domain,
(c) Providing information the company believes is clearly nonmaterial.
(d) Discussing generally the factors that might influence the underlying assumptions used for future projections.
2. Review of Earnings Models — The Investor Relations Department should not review earnings models.
3. Analyst Meetings/Conference Calls — All analyst meetings/conference calls (to discuss other than quarterly and annual financial and business information) should be simultaneously broadcast over the internet or via telephone conference call to all interested members of the public. Appropriate advance notice of the meeting and the simultaneous broadcast, in light of the communication, should be made in a press release or other method of communication in compliance with Regulation FD.
Product Pipeline Information
The following information regarding the pipeline of new drugs (including line extensions) may be disclosed: