Relying on
existing company policies and procedures, and supplementing
them with US federal laws, US SEC rules and regulations, US
stock exchange regulations, best corporate governance practices,
and local non-US regulator requirements, an information disclosure
procedure manual is generated.
This manual, called Disclosure Handbook, will answer any doubts
about best practice procedures in material information disclosure
to the financial markets. Its cross reference and procedure
forms structure will assist the company in effectively communicating
with the investor and analyst community, removing doubts as
to what, when and how to disclose.
Important: The Disclosure Handbook illustration assumes
a fictional non-US company listed in both the US and its market.
The procedures will be adjusted to suit your company profile.
Step 2 - Approval and Filing of Disclosure Handbook
Subsequent to its generation, the Disclosure Handbook is evaluated by a series of parties to verify its reliability and compliance with existing rules, regulations and best practice procedures existing in the company’s reporting regime(s).
After the first draft, a review committee made up of MZ Consult
and Linklaters, revises the manual’s content relying on their
respective and legal market expertise. Once both the review
committee and the company find the manual satisfactory, the
Disclosure Handbook is submitted to the company’s Board of
Directors.
The Board of Directors will also review, amend, if necessary, and adopt the Disclosure Handbook. Subsequent to Board ratification, the manual is filed with the exchange regulators and governing bodies of the company’s reporting regime(s).
Upon completion of these approval stages, the company is now ready to start adopting the procedures and practices defined in its Disclosure Handbook, and prepare for KPMG’s review scheduled to take place after the company’s first two disclosure procedures.
Step 3 - Disclosure Handbook Implementation and Procedures Review
The practices and procedures defined in the Disclosure Handbook are ready to be put into place. Upon filing the manual with the appropriate parties, the company will adopt the prescribed procedures and prepare for its KPMG review scheduled to occur subsequent to its first two disclosure processes.
KPMG will review the company’s procedures and issue a findings report indicating whether or not the agreed upon procedures were followed. The report will be sent to both the company as well as MZ Consult, the party in charge of delivering the seal.
Assuming a positive findings report, the company is now ready to receive its Exemplary Disclosure™ seal.
Step 4 - Certificate of Compliance
Having gone through all the necessary approval processes,
the company is now ready to receive the seal indicating that
it has been in compliance with its Disclosure Handbook. Indeed,
subsequent to satisfactory findings report issued by KPMG,
MZ Consult will award the Exemplary Disclosure™ seal to the
company.
The seal will be valid for a period of 6 months, but can easily
be renewed at that time. An Exemplary Disclosure™ company,
will undergo semi-annual reviews by KPMG, as long as it wants
to maintain this denomination. The process will be the same
as that described in Step 3. KPMG will issue a findings report
which will be sent to both the company and MZ Consult. Once
again, assuming a positive report, MZ Consult will renew the
seal.
Step 5 - Certification Renewal
Certification renewal is determined by the resulting findings reported in KPMG’s the semi-annual reviews of Exemplary Disclosure™ certified companies. Assuming KPMG’s findings report is satisfactory, confirming ongoing compliance of the company with agreed upon procedures, MZ Consult will reissue the seal, valid for another 6 months.