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Disclosure Policy
Purpose
The purpose of this policy is to ensure:
- fair disclosure of information about Silver Standard and its strategic objectives, on a consistent basis, to the public;
- timely, factual and accurate of disclosure of material information to the public; and
- compliance with all applicable securities laws.
This Disclosure Policy shall be posted on our web site: www.silverstandard.com.
Material Information - Definition
Material information is any information relating to the business and affairs of a company that results in or would reasonably be expected to result in a significant change in the market price or value of any of the company’s listed securities.
Application
This policy applies to all of our directors, officers, employees and consultants and covers all disclosure of information (material and non-material information and electronic, written and oral disclosure) about or relating to Silver Standard and its business, projects, joint ventures and subsidiaries.
Disclosure Committee
A Disclosure Committee has been formed to oversee the disclosure of information (electronic, written and oral) by Silver Standard and administer this Disclosure Policy. The Disclosure Committee shall initially be comprised of the President and CEO, the Director, Investor Relations and Senior Vice President, Corporate
The Disclosure Committee will (a) meet on a monthly basis and as otherwise required and (b) review and update this policy as necessary.
The Disclosure Committee may make and adopt procedures governing the implementation of parts of this policy.
Designated Spokesperson/Representatives
All communication of information about or relating to Silver Standard and its business to the investment community, the media, shareholdersor other members of the public shall be made through the President and CEO, Director of Investor Relations, Investor Relations Coordinator or Senior Vice President, Corporate. No other directors, officers, employees or consultants are authorized to respond to inquiries from the investment community, the media, shareholdersor other members of the public, unless authorized by the President and CEO, or in his absence, the Senior Vice President, Corporate.
The Director, Investor Relations and the Investor Relations Coordinator may respond to day-to-day inquiries in accordance with disclosure agreed upon by the Disclosure Committee ("Permitted Disclosure"). No comments or personal opinion shall be made on or off the record to the investment community, the media, shareholdersor other members of the public that are not consistent with the Permitted Disclosure.
Any questions regarding whether to communicate information about or relating to Silver Standard to the investment community, the media, shareholdersor other members of the public shall be referred to the Senior Vice President, Corporate.
Disclosure of Information
Approval by Disclosure Committee
All proposed (a) disclosure of material information (not previously disclosed), (b) speeches, presentations "road show materials" and (c) information packages and web site postings must be approved by the Disclosure Committee.
News Releases
We shall disclose to the public through news releases all material information concerning our business and affairs forthwith upon the information becoming known to management, or in the case of information previously known, forthwith upon it becoming apparent that the information is material, other than in certain limited circumstances approved by the Disclosure Committee. Immediate release of information is necessary to ensure that it is promptly available to all investors and to reduce the risk of persons with access to the information acting upon undisclosed information.
The Director, Investor Relations shall be responsible for the preparation and dissemination of all news releases in compliance with this Disclosure Policy and stock exchange requirements.
News releases shall be disseminated to the public by the quickest possible method and in a manner that provides for wide and simultaneous dissemination. Each news release must be distributed to news dissemination services that disseminate the full text of news releases without editing, and that distribute financial news nationally, to the financial press and to daily newspapers that provide regular coverage of financial news and events. All news releases shall be disseminated through our primary news release dissemination service, unless otherwise approved by the Disclosure Committee. The primary news release dissemination service shall be a TSX recognized full text news service.
News releases shall also be disclosed whenever possible directly through any one or more of Reuters, Dow Jones, Bloomberg and other services providing wide dissemination of information. The use of these services is complementary to and not in substitution for our primary news release dissemination service.
The Disclosure Committee shall be responsible for monitoring the performance of the primary news release dissemination service and taking any necessary remedial action.
Email/Fax Lists
Following confirmation of the dissemination of the full text of a news release by the primary news release dissemination service, a news release may be faxed or emailed to parties who have requested to be included on Silver Standard’s email/fax list.
Telephone Inquiries
Only designated spokesperson/representatives shall respond to telephone inquiries.
Investor Conferences
We will post on our web site in advance all investor conferences we plan on attending and those at which we have been asked to make a presentation.
Only previously disclosed material information and non-material information shall be disclosed at investor conferences. In the event material non-public information is inadvertently disclosed at an investor conference, such information shall promptly be disclosed to the public by way of a news release.
Whenever possible, (a) web casts of presentations by our representatives and (b) presentation materials shall be linked/posted on our web site as soon as possible after the presentation.
Conference Calls/Web Casts
In the event we hold conference calls/web casts with analysts and investors, we will announce the conference call/web cast by news release and posting on our web site at least one day prior to the call/web cast, unless special circumstances require shorter notice. A recording of the conference call/web cast will be made available for at least 48 hours following the call.
Securities Filings
The Senior Vice President, Corporate or designated nominee shall review and approve all securities filings prior to filing with regulatory authorities or stock markets.
Analysts
Draft Analyst Reports and Models
If requested, we will review draft analyst reports and models, but only to confirm factual accuracy of publicly disclosed information and to correct non-material information. All reviews of draft analyst reports must be approved by the Disclosure Committee.
Meetings with Analysts
Only previously disclosed material information and non-material information shall be disclosed at meetings with analysts. In the event material non-public information is inadvertently disclosed to an analyst, such information shall be promptly disclosed to the public by way of a news release.
Analyst Reports
We will not publicly comment on analyst reports on Silver Standard or its peer group of companies.
We will not post analyst reports on our web site or circulate these reports to the public. If requested, we may refer shareholders and other members of the public to web sites that make available analyst reports on Silver Standard, but only if the web sites make available all analyst reports on Silver Standard.
Analyst reports may be provided to certain of our directors, officers and employees for information purposes.
Web Site
The Director, Investor Relations shall be responsible for ensuring that our web site (a) is kept up-to-date, including the posting of news releases as soon as possible after dissemination to the public and (b) complies with this Disclosure Policy.
Market Rumours
Our practice is not to comment on market rumours. If requested by a regulatory authority or stock exchange to issue a news release in respect of a market rumour, the Disclosure Committee will review the request and determine the appropriate response.
Trading Restrictions
Directors, officers and employees with access to non-public material information shall not trade our shares until the information has been disclosed to the public and a reasonable period of time has elapsed following the release of the information.
The Disclosure Committee may impose trading blackouts on certain employees during which they cannot trade our shares.
Contact
Copies of our publicly disclosed documents are available on our web site www.silverstandard.com or may be obtained by contacting Investor Relations at 1-888-3380046.