Avoiding Accidental IR

or, What Not to Tweet

Chris Gatewood@gatewood5000

www.thresholdcounsel.com

NIRI RichmondNovember 2011

Social Media and IR

Two worlds

Pizza is your best defense

Two Worlds

Yours: Investor relations professionals

Theirs:Anyone else within your company

Social Media is another IR channel

Coordinate the SM channel

• simultaneous news releases

• avoid selective disclosure (Reg FD) .@

• think company-wide

• monitor

Your world: IR Involvement

Common kinds of coordination

Your world: IR Involvement

Statements made via social media are subject to regulation, just like other company communications.

Let’s be clear

Disclaimers

• GAAP reconciliations

• forward-looking statements

• tough on Twitter

Your world: IR Involvement

Context to Links• Attribution of news and analysis, not

endorsement

• Equal time to analyst news pro and con?

Beware of• Price targets

• Account settings, keep it public (Reg FD)

• Side conversations

• Inconsistency between channels

Your world: IR Involvement

Yesterday:

IR meets PR

Money

Work

Manage Risks• Develop SM policies

• Training – where the pizza comes in (and share the pizza, not just in IR)

• Practices both in-office and away

Their world: Other messengers

Any employee can be a spokesperson