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SHAREHOLDER COMMUNICATION POLICY
In order to deal with all shareholders equally and according to appropriate rules and regulations, NeoMedia Technologies, Inc., and its Subsidiaries (“NeoMedia” or the “Company”) will follow this standard procedure in communicating with all shareholders, and will receive directions from the disclosure committee and the IRO at NeoMedia.
1. NeoMedia will not comment to shareholders individually as all shareholders need to be informed about material developments simultaneously. Such comments could constitute selective disclosure, which is the release of material non public information to any individual or group prior to the broad public dissemination of that information. It is against the law and Company policy to selectively disclose material, non public information.
2. NeoMedia will take steps to ensure that material and other sensitive information will be carefully handled in order to avoid “selective disclosure.” The Company will maintain a disclosure committee which is responsible for making the determination of what they deem to be material information and the timing of its dissemination.
3. NeoMedia has always, and will continue to keep shareholders apprised of any material information, in line with what is expected from a public company.
4. As part of these efforts, NeoMedia may choose to hold investor conference calls
5. NeoMedia understands the importance of, and is committed to, shareholder communications. As a public company with limited resources, our first duty is to run the business in the best interest of all of our shareholders. We try to be as responsive as possible with shareholders by trying to anticipate questions and by responding to questions via email (IR@qode.com)
6. Only authorized NeoMedia spokespersons will speak with shareholders at previously arranged, formal communication events such as conference calls and road shows. Authorized spokespersons are appointed by the Investor Relations Officer and may change from time to time.
7. NeoMedia will not comment to shareholders on rumors or speculations.
8. All members of our Board of Directors, Officers, employees and consultants are to review and follow this policy at all times. All questions related to this policy must be reported to IRO. This policy will be strictly enforced.
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