Bon-Ton is committed to full and fair disclosure of information investors need to make informed decisions. Our commitment is to provide realistic expectations for the Company's external stakeholders in compliance with laws and regulations.
SCOPE
Applicable to all employees, officers and directors of the Company, and any business partners, this disclosure policy addresses verbal and written communications with media, financial analysts, and existing and potential investors. Communications vehicles include press releases, print and audio/video materials, interviews given by executives, presentations, advertising and promotion, telephone conversations and the Internet.
AUTHORIZED COMPANY SPOKESPERSONS
Investors, analysts and reporters often want to speak directly with our executives and we make them available as schedules permit. We normally schedule several occasions a year when interested groups can meet Company executives personally to reduce the need for such contacts
The designated Company contact for the financial community is Mary Kerr, Vice President, Investor Relations. Ms. Kerr can be reached at 717-751-3071 or by email at mkerr@bonton.com. Other authorized spokespeople are the Chief Executive Officer, President and the Chief Financial Officer.
No other Bon-Ton associate (including rotators and vendor representatives), officer or director is authorized to answer inquiries or discuss the financial or operating affairs of the corporation with members of the financial community without the prior approval of Ms. Kerr or Keith Plowman, Executive Vice President, Chief Financial Officer and Principal Accounting Officer. This includes sales performance, sales by store, department or vendor, profit projections, comparative data, etc.
GUIDELINES
To accomplish our objectives, we periodically release to the public information we believe may reasonably be expected to affect the market value of the stock or investors' attitude toward it. However, it is our policy not to comment on rumors or on market activity in our stock. Our public disclosure is accomplished through press releases, our annual report, quarterly updates, required SEC filings, and conference calls open to the public.
At times, we answer reasonable questions of a nonmaterial nature during telephone calls and in-person meetings with stockholders or the financial community. In the event any material information is inadvertently disclosed during such calls or meetings, a press release with respect to such material information will be issued within 24 hours or before the market opens the next business day. We will review analysts' detailed models and reports only on the basis of (1) errors of historical facts that are in the public domain, and (2) fully published information.
PROJECTIONS
All forward looking statements regarding earnings forecasts or projections will be made public through the issuance of a press release. All comments pertaining to forecasts will refer to our most recent publicly disclosed statements and our guidance. We will not express comfort or lack of comfort with analysts' expectations. If events or market forces will materially affect results that we have communicated in our forward looking comments, we will publicly disseminate this information so that others may draw their own conclusions as to how it may affect future operating results.
We will not normally comment on the estimates of others, though we may comment on the assumptions they have used in predicting our results if these assumptions differ markedly from our own. We will discuss publicly available material information and address business issues of a nonmaterial nature with investors and the financial community.
PUBLIC ANNOUNCEMENTS
Our schedule of quarterly announcements can be obtained from the Investor Relations Department. One week before the end of each quarter, company contacts will not answer questions specifically on performance, although they may answer questions dealing with very routine operational matters.
From time to time we may announce material events prior to the date of our periodic SEC filings. We will do so when we believe there is a material change in the financial condition or operations of the Company. Absent any such announcement, as a matter of policy, the Company will issue a "no comment" response to rumors and inquiries regarding potentially material events.
Bon-Ton may choose a combination of disclosure methods to achieve broad, non-exclusionary distribution of information to the public. A planned material disclosure of information will be handled as follows:
We will issue a press release, distributed across a major newswire, containing the information. This press release will also be posted on our website.
If required by SEC rules, we will file a Form 8-K.
If a conference call or webcast is to be held, we will provide notice of the call in the press release, giving both the time and date of the call and instructions on how to access the call.
We will hold the call in an open manner, permitting anyone to listen in either by telephonic means or through Internet webcasting. We may limit the individuals or entities permitted to ask questions.
PUBLICATIONS
We routinely distribute annual reports, Form 10-Ks, Form 10-Qs and other items of interest to the financial community. These items can be downloaded from the company's website at www.bonton.com. Materials concerning our corporate governance can also be found on our website.
Our company website offers email alerts whenever new information is posted to our website. You may register for this service on our website. If you would like to add your name to our mailing list, write or call the investor relations department:
Ms. Mary Kerr
The Bon-Ton Stores, Inc.
P O Box 2821
York, PA 17405
(717) 751-3071 mkerr@bonton.com
LIMITS ON INFORMATION PROVIDED
We will attempt to answer questions as fully and promptly as possible, but there are certain limits. We release comparable store sales in total and indicate which areas are above or below the company average. We only give general information on the performance of separate stores. We review these limits periodically and change them as warranted.
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