Section 303A.10 requires that any waiver from a companys code of business conduct and ethics must be promptly disclosed to shareholders. What would constitute prompt notification?
The distribution of a press release within 23 business days of a boards determination to approve any waiver from the companys code of business conduct and ethics is an example of prompt notification. A company might also choose to provide website disclosure of any waiver, or provide notice to the SEC on Form 8-K. These examples, however, are not intended to provide an exclusive list of alternatives. Section H – Questions on Section 303A.11 – Foreign Private Issuer Disclosure 1) Section 303A.11 requires that foreign private issuers disclose any significant ways in which their corporate governance practices differ from the NYSE domestic corporate governance standards either in the annual report required by the NYSE to be distributed to U.S. shareholders or on the companys website. If the company chooses to provide the disclosure on its website, when must it do so? As of the companys Section 303A compliance date, if the company chooses to include the required disclosure on its website, it
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- Section 303A.10 requires that any waiver from a companys code of business conduct and ethics must be promptly disclosed to shareholders. What would constitute prompt notification?
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