Friday, March 16, 2007 10:40:01 AM
Investor Relations
Shareholder Communication Policy
In order to deal with all shareholders equally and according to appropriate rules and regulations, NeoMedia will follow this standard procedure in communicating with all shareholders, and will receive directions from the disclosure committee and Walek & Associates, 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 nonpublic 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, nonpublic 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 will hold quarterly earnings 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 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@neomedia.com)
6. NeoMedia will then try and address the question(s) on the FAQ section (soon to be released) of NeoMedia’s website at www.neom.com. We will get you an answer if your question is appropriate given materiality and Fair Disclosure issues. We will then post your question and answer on the FAQ section of the IR Web site. Please refer to this section before emailing a query, and refer to it often, as we update it frequently. Your question may already be asked and answered.
7. For Neomedia employees; all emailed requests by shareholders should be forwarded to:
Peter Moore I Walek & Associates, office: 212-590-0533 I pmoore@walek.com
8. Only authorized NeoMedia spokespersons will speak with shareholders at previously arranged, formal communication events such as conference calls and road shows. Authorized spokespersons are the CEO, Legal Counsel, CFO, COO and others appointed by the Investor Relations Officer.
9. NeoMedia will not comment to shareholders on rumors or speculations.
10. All employees, board members and consultants to NeoMedia are to review and follow this policy at all times. All queries must be reported to IRO and Walek & Associates. This policy will be strictly enforced by management and all directors will sign this policy upon joining the board.
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