Shareholder Contacts Policy
1. Purpose
Green Earth Group N.V. (the "Company") is listed on Euronext Amsterdam. The Company aims for a transparent and open dialogue with its shareholders. This policy sets out how the Company deals with contacts with shareholders, and in particular with bilateral contacts.
2. Scope
This policy applies to all contacts between the Company and its shareholders, both at the General Meeting and outside it.
3. Definitions
- Board: the management board of the Company, made up of executive directors and non-executive directors.
- Bilateral contact: a contact between the Company and one or more individual shareholders outside a General Meeting.
- General Meeting: the general meeting of shareholders of the Company.
4. Equal and simultaneous information
- The Company informs all shareholders at the same time and to the same extent about its strategy and its operational and financial performance.
- Periodic financial reporting may be accompanied by bilateral meetings.
- In line with applicable laws and regulations, the Company makes information that is or may be price-sensitive, or that is otherwise relevant, generally available without delay by means of a press release.
5. Contacts with shareholders
- Contacts with shareholders take place only within the periods opened for that purpose (see section 7).
- Contacts with shareholders take place primarily at the General Meeting.
- Bilateral contacts outside the General Meeting can also be of value to both the Company and its shareholders. In these contacts, the Company mainly explains information that has already been published, such as the existing strategy and business results.
- The Company is not obliged to accept an invitation from a shareholder to meet.
- The Company may at any time ask a shareholder who wishes to meet the Company to disclose the size of their interest in the Company.
- No separate presentations are prepared for, or given during, bilateral contacts with shareholders.
- In contacts with shareholders, the Company is in principle represented by the Board or one of its members.
6. No price-sensitive information in bilateral contacts
- The starting point is that no price-sensitive information is provided in any contact with shareholders.
- If price-sensitive information is provided by mistake in a contact with shareholders, the Company makes that information generally available without delay by means of a press release.
The Insider Trading Regulations contain the rules on handling inside information.
7. Closed periods
As a rule, no bilateral contacts take place:
- during the 30 days before the publication of the annual or half-year results; and
- during the 30 days before the publication of other financial information, such as trading updates.
8. Roles and responsibilities
| Post | Responsibility |
|---|---|
| Board | Represents the Company in contacts with shareholders, in principle through the Board or one of its members. Adopts and amends this policy. |
| Head of Legal | Owns this policy. |
9. Reporting concerns
Concerns about compliance with this policy can be reported under the Whistleblower and Non-Retaliation Policy.
10. Approval and review
- The Chief Executive Officer approves this policy and any amendment to it on behalf of the Board.
- The Head of Legal owns this policy and reviews it at least every two years.
History: the first version of this policy was adopted by the board of the Company, then named DGB Group N.V., on 8 January 2018.
