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Please see attachments

Communications Policy

Due Monday, October 1, 2012.
Prepare a Communications Policy Document that maps the type of communications messages (e.g., organizational or strategic changes, procedural changes, information important to organizational sub-groups, confidential information, unwelcome information, etc.) to the audience; media to be used (including social media); the appropriate approvals required; and tools and tactics. This document will be 8 to 10 pages. Utilize at least five peer-reviewed articles in addition to readings from the textbook and online resources.

The following Web sites can be used as references for the document to be created (also attached):

· http://www.swedishmatch.com/Documents/Policies/CorporateCommunicationsPolicy_EN

· http://www.une.edu.au/policies/pdf/communicationpolicy

Universityof New England

COMMUNICATION POLICY

Document data

Document Type Policy and Procedures

Administering entity Information Technology Directorate on behalf of

Pro Vice Chancellor Academic

Date approved 22
nd

November 2005

Approved by Information and Communication Technology

Committee

Indicative time for

review

Annually

Responsibility for review Director, Information Technology

Related policies or other

documents

TRIM Reference No.

D09/34612

1. Rationale and Scope
1.1 Scope

This policy applies to staff, student and affiliates of the University of New England.

1.2 Official Communication Mechanisms
UNE uses both printed mail and electronic communication channels as official communication

mechanisms to communicate official notes to staff and students. Depending on the nature of the

notice and at the discretion of the originator of the notice, one or both mechanisms may be

used; whenever possible, preference will be given to electronic communication.

2. Principles
2.1 The Policy will be made publicly available and communicated to the University community.
2.2 This policy is to be read in conjunction with the related policies and documents list above, any

other relevant University policy documents and relevant State and Federal legislation.

2.3 Change to this policy must be made in accordance with University of New England (UNE)
planning guidelines.

2.4 This policy will be reviewed every twelve months.

3. Policy
The University of New England is moving away from paper based communication and is

increasingly using electronic communication channels to conduct its business with staff

members and students. This policy outlines the official communications mechanisms used by

the University of New England to communicate official notices and other communication and

covers printed communications (mail outs) as well as electronic communication through email,

a web portal or UNE’s website

4. Procedures
4.1 Electronic Communication
4.1.1 UNE will use electronic communication channels (such as email, a UNE portal or websites)

as official communication mechanisms and will use them to communicate with staff

members and students about administrative matters.

4.1.2 All current staff members and enrolled students are provided with an email account, which
must be activated as soon as possible after the beginning of employment (staff) or

enrolment (students).

4.1.3 Students and staff members must check their email account at a minimum weekly to be
informed of information that UNE is communicating to them.

4.1.4 Students may choose to forward their UNE email to another internet service provider. It is
the student’s responsibility to keep their email forwarding details up to date.

4.1.5 When the University initiates contact with students and staff members by email, the
University will use the UNE email address.

4.1.6 When a student initiates contact with the University, the University prefers use of the UNE
email address. If, however, students contact the University from an email address other than

their UNE address, wherever practically possible UNE will use the non-UNE address for its

reply.

4.2 Printed Mail
4.2.1 When communicating with staff members by paper mail, the University will use either the

internal department address or the current mailing address provided by the staff member.

4.2.2 When communicating with students by printed mail, the University will use the currently

mailing address provided by the student.

4.2.3 It is the responsibility of staff members and students to keep their mailing address details

up to date and inform UNE of any changes.

5. Exemptions
5.1 Under special circumstances alternative contact mechanisms may be arranged where student or

staff members are unable to receive either electronic or printed communications.

5.2 Students wishing to arrange alternative contact mechanisms must notify Student
Administration. Staff members wishing to arrange alternative contact mechanisms must notify

Human Resources. Both staff and students must follow the process outlined in the

Communication Guidelines (above).

6. Definitons:

UNE – University of New England
Official Communication – Any communication between the University and its staff or
students on matters relating to the relationship between the University and its staff members or

students. Examples include but are not limited to correspondence regarding admissions,

enrolment, examinations, fees, financial matters, results or timetabling for students or policy

matters or employment conditions for staff.

Corporate Communications Policy

Issue date: 2005-12-20

Issued by:

SVP Corporate Communications and

Sustainability

Version: 1.3

Date of last revision: 2011-12-15

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CONTENTS

1 Introduction …………………………………………………………………………………….. 4

2 Goals ………………………………………………………………………………………………. 4

2.1 Main goals for external communications: ……………………………………….. 4
2.2 Main goals for internal communications: ………………………………………… 4
2.3 Key words for communication ………………………………………………………. 5

3 Division of responsibilities ………………………………………………………………… 5

3.1 Responsibilities for external communication …………………………………… 5
3.2 Responsibilities for internal communication ……………………………………. 7

4 Restrictions and confidentiality ………………………………………………………….. 8

5 Coordination ……………………………………………………………………………………. 9

6 Updates …………………………………………………………………………………………… 9

7 Crisis communication ……………………………………………………………………….. 9

8 Distribution, confirmation and implementation of this document …………… 9

Appendix 1 Internal communication ……………………………………………………… 11

Appendix 2 External communication …………………………………………………….. 12

1. Investor Relations ………………………………………………………………………. 12
2. Media relations ………………………………………………………………………….. 14
3. Other external information and social information …………………………. 15

4. Guidelines for sponsorship activities …………………………………………….. 15

Appendix 3 Corporate website ………………………………………………………………. 17

Appendix 4 Stock market information …………………………………………………. 18

Publication ………………………………………………………………………………………….. 18

Information leaks …………………………………………………………………………………. 19

Contacts with analysts …………………………………………………………………………… 20
Comments on analysts’ profit forecasts …………………………………………………… 21
Meetings with investors and analysts ………………………………………………………. 22

One-on-one meetings ……………………………………………………………………………. 23

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1 INTRODUCTION

Communication plays a critical role within Swedish Match. As a listed company,

Swedish Match must comply with relevant legislation, regulations and standards

concerning securities markets and financial reporting.

The Swedish Match Communication Policy is an important aspect of our continual

efforts to build up global trust in the corporate brand. It has been adopted by

Swedish Match’s Board of Directors to provide guidelines for how communication

should be conducted to ensure that it is in accordance with the Swedish Match

Group’s interests. In today’s global information society, however, requirements and

standards are constantly changing, and accordingly, Swedish Match’s

Communication Policy will be scrutinized and revised on an ongoing basis.

The Communication Policy provides guidelines for how Swedish Match’s managers

should act in their daily communications with employees and external stakeholders.

The policy primarily covers objectives, division of responsibilities and general

guidelines for communicating with various target groups. It also provides guidelines

with regard to who can act as a spokesperson for the Group and addresses the rights

of employees to state their opinions. Detailed guidelines for communications are

provided in the appendices.

2 GOALS

The main purpose of Swedish Match’s Communication Policy is to establish

guidelines for presenting the Company to current and potential stakeholders, both

internally and externally. Furthermore, the policy is aimed at increasing the level of

understanding among all employees as to how Swedish Match communicates with

its stakeholders.

2.1 Main goals for external communications:

Support the business concept and strategies
Strengthen confidence in the Swedish Match Group, the Swedish Match brand,

its employees, management, and products
Share information with regard to Public and Scientific Affairs
Meet expectations concerning Swedish Match’s compliance with legislation,

regulations and standards relating to communication activities
Support a correct evaluation of the Swedish Match share and facilitate the

raising of capital by giving as accurate a picture as possible of the Group’s

financial position
Manage the image of Swedish Match, its products, and activities Facilitate

recruitment of employees

2.2 Main goals for internal communications:

Make sure that the Company’s goals, policies and guidelines are communicated

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Strive to give employees the information they need, when they need it, in order

to increase understanding and commitment, build motivation, and support

company strategies

Communicate with employees about decisions and events that affect them before

(if possible) and never later than when information is communicated externally

Contribute to the Swedish Match Group’s business objectives
Increase each employee’s knowledge about the Swedish Match Group and its

development
Enhance employee’s knowledge of Swedish Match’s business objectives,

strategies and values
Provide clear and current information to employees on Group policies and

information vital to the Group with regard to corporate branding (Corporate

Identity)
Internally disseminate success stories and good business solutions throughout

the organization, in order to spread creativity and encourage cross-operating unit

cooperation

2.3 Key words for communication

The Swedish Match Communication Policy governs how we behave and establishes

rules and standards for our day-to-day communication. The key words are:

correct proactive well-planned
factual long-term simultaneous
pertinent consistent adapted to target groups
rapid

3 DIVISION OF RESPONSIBILITIES

3.1 Responsibilities for external communication

The CEO is ultimately responsible for ensuring that Swedish Match’s

communications are in compliance with the Communication Policy. The Chief

Executive Officer (CEO) has delegated strategic responsibility for communication

matters to the Senior Vice President (SVP) of Corporate Communications and

Sustainability, who reports to the CEO. Communication with regard to Public

Affairs and Scientific Affairs are the responsibility of the SVP Legal Affairs.

All ongoing contacts with shareholders, analysts, fund managers, business media

and other actors on the capital market are handled by Investor Relations. The

primary contact in this regard is the SVP of Corporate Communications and

Sustainability.

3.1.1 Spokespersons

In order for Swedish Match’s communications to live up to the Company’s policies

and goals, it is essential that the Group’s spokespersons are those individuals with

the best expertise and overview. Only designated spokespersons are permitted to

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issue statements on behalf of the Swedish Match Group. These persons must have

access to relevant information about the Group’s position and performance and

about their particular areas of expertise. They must also be fully familiar with the

NASDAQ OMX Stockholm rules and standards concerning information. Swedish

Match reacts to information leaks and rumors only if these could seriously damage

the Group. Otherwise, the standard reply is: “We do not comment on rumors.”

The Chairman of the Board and the Deputy Chairman of the Board may issue

statements on pertinent issues arising from the Board’s responsibility for ownership

issues, strategies, nominations, appointments, compensation, and corporate

governance of the Company. Other Board members are not permitted to make

statements without prior consultation with and approval from the Board Chairman.

For the purpose of facilitating the Nominating Committee’s evaluation of the Board

of Directors, the Board members, upon request from the Nominating Committee, are

obliged to participate in interview sessions with the Nominating Committee. Such

interviews should preferably be conducted in a controlled manner and core findings

documented.

Statements by Board members should in this regard be restricted to the working

procedures of the Board of Directors, expertise and experience within the Board in

relation to actual and future business environment for the Company, and related

matters. Board members should not discuss company related information which has

not been publically disclosed by the Company.

The CEO is the principal spokesperson for Swedish Match on group-wide matters,

including but not limited to the Group’s financial position, business strategies,

market assessments and competition analyses.

After the CEO, the SVP of Corporate Communications and Sustainability serves

as the Group’s main spokesperson to the media and the general public and selects

suitable individuals to respond to specific questions from the media and the public.

The Chief Financial Officer (CFO) is responsible for ensuring that financial

reporting and information complies with the applicable legislation, regulations and

standards. After the CEO, the CFO is the main spokesperson in contacts with

financial market representatives, including the media.

The Investor Relations function, is responsible for all communication with

analysts, shareholders and business and financial journalists. Investor Relations also

deals with ongoing contacts with investors, analysts and business and financial

journalists. The SVP of Corporate Communications and Sustainability is the

Investor Relations spokesperson, along with the CEO and CFO. Other individuals

may also be designated by the CFO to communicate with the above stakeholders.

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Communication with regard to Public Affairs and Scientific Affairs are the

responsibility of the SVP Legal Affairs, who may designate certain managers to

communicate on behalf of the

Company.

Other Senior Executives and operating unit Presidents or COOs are entitled to

make statements concerning current operations within their particular areas of

responsibility, but not regarding circumstances that could potentially affect the share

price. Media contacts or other external contacts of material importance must be

reported to the Group’s Corporate Communications and Sustainability department.

Other employees are not permitted to make statements on behalf of the Group, but

are not prevented from making personal statements (in social media, for example).

In such cases, the employee concerned must state clearly that his/her statement is

from a personal viewpoint, and does not necessarily reflect the views or opinions of

the Company or management.

3.2 Responsibilities for internal communication

3.2.1 Corporate responsibilities

Group Corporate Communications and Sustainability has operational responsibility

for internal communications.

All relevant and current corporate information is disseminated via Intranet, such as

policies, internal news, tobacco related news, organizational changes, vacancies,

articles, financial information, links to important business tools, etc. The importance

of this communication channel is such, that it should be considered as the main

source of corporate information to Swedish Match employees. Corporate

Communications and Sustainability has the responsibility to develop internal

communications structures that ensure that the Company reaches all employees as

quickly as possible via the most efficient communications channels.

The Group’s corporate language is English. Consequently, internal communication

should be produced in English.

Group Corporate Communications and Sustainability is also responsible for

developing and maintaining, via the Swedish Match Corporate Identity Manual,

guidelines for the Swedish Match Group’s Corporate Identity and graphical

appearance. All operating unit heads (President or COO) are responsible for

ensuring that the organizations for which they are responsible follow these

guidelines, and for consulting with Group Corporate Communications and

Sustainability in this regard.

3.2.2 Operating unit responsibilities

The Group’s operating units are responsible for:
Ensuring access for employees to the corporate information published at the

Intranet
Running the local information process at operating unit workplaces and offices

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Cooperating with Group Corporate Communications and Sustainability to

facilitate internal communication flows and to communicate in line with Group

strategiesEnsuring that information material produced locally – such as

newsletters, other publications and websites – conforms to the Group’s

guidelines as well as to legislation, regulations and standards. Internal

information is published under the responsibility of the operating unit head
Internal information intended for group-wide distribution must be coordinated

with Group Corporate Communications and Sustainability, see above 3.2.1
Local information is given in the local language and/or English

3.2.3 Employee responsibilities

Managers within Swedish Match have an important responsibility to

communicate in a professional manner. Communication should be integrated in

strategic planning and implementation and ensure that appropriate resources are

allocated for this. If needed , the manager should ask for advice from his or her

communications contact

4 EMPLOYEES SHOULD FEEL THAT THEY HAVE A
COMMUNICATION RESPONSIBILITY – TO TAKE IN
INFORMATION THAT IS COMMUNICATED, TO SHARE
INFORMATION AS APPROPRIATE, AND TO CONTRIBUTE TO
DIALOGUERESTRICTIONS AND CONFIDENTIALITY

Internal and external communications are subject to various restrictions resulting

from legislation, regulations, standards and agreements relating to the stock market,

customers and terms of employment as well as business considerations, for example,

our agreements with NASDAQ OMX Stockholm, as well as other applicable

legislation governing securities markets, securities trading and financial reporting.

The Swedish Match corporate culture is characterized by open and trusting

communication at all levels of the organization and between all groups of

employees. This helps employees to become more involved in and committed to the

Company’s development. However, employees are bound by professional

confidentiality with regard to all information that is for internal use, relates to

customers or competition, or could potentially be price-sensitive. Appendix 4, Stock

market information provides examples of the types of information that are to be

regarded as being potentially price-sensitive. In the event of uncertainty regarding

confidentiality issues, employees must contact their immediate superior, Corporate

Communications and Sustainability, or the local or corporate legal department.

In conjunction with customer negotiations about future projects or partnerships,

acquisitions or divestments of operations, or other transactions that could potentially

affect the share price, only those who absolutely need to be involved in the matter

should be informed. Special rules apply for such situations
1
.

1
See Appendix 4, Stock market information

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When an external party asks to speak to an employee at Swedish Match who is not

available, the person’s destination or business should never be disclosed.

5 COORDINATION

In order for the Chairman, CEO as well as heads of Corporate Communications and

Sustainability and Group Finance to be able to act with authority as spokespersons

for external and internal communications, it is essential that these individuals are

kept informed about pertinent activities in all parts of the Group, and about

questions originating from external stakeholders. This procedure helps to ensure

high-quality communication and identifies where in the organization the ultimate

responsibility for information lies.

Executive management and other managers are informed about Group and industry

news and about articles and features in external media through reports from the

operating units and via news coverage services and the Intranet.

Coordination is primarily the responsibility of the head of Corporate

Communications and Sustainability, and presupposes that these persons are highly

familiar with the Group’s operations and have full insight into relevant

developments. Coordination also entails responsibility for establishing and

maintaining continual, organized contacts and information flows throughout the

entire organization.

6 UPDATES

The CEO is responsible, in consultation with the head of Corporate Communications

and Sustainability and other members of Group management, for ensuring that the

Swedish Match Communications Policy is developed, updated, distributed and

complied with.

7 CRISIS COMMUNICATION

A crisis is a situation in which events beyond Swedish Match’s control threaten to

damage the Swedish Match Group’s relations with its shareholders, customers and

employees, or its reputation, financial position or other vital interests.

A Crisis Management Team has been assembled to handle crises. Corporate

Communications and Sustainability is responsible for managing all internal and

external communication during a crisis situation that could adversely affect the

Group. For further details, see the Swedish Match Crisis Manual.

8 DISTRIBUTION, CONFIRMATION AND IMPLEMENTATION
OF THIS DOCUMENT

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This policy is to be distributed to the following groups of persons and must be

confirmed in accordance with the matrix below.

Confirmation required for this policy Received Read Implemented

GMT X X

SVP Corporate Communications and
Sustainability

X X X

Head of operating unit X X X

By confirming that the policy document has been RECEIVED, the recipient
confirms that they are aware that the policy exists.

By confirming that the policy document has been READ, the recipient
acknowledges having read and understood the contents of the policy.

Confirming that the policy document has been IMPLEMENTED means that
the recipient

– has informed all pertinent persons within his/her respective unit (i.e.,
company) of the contents of the policy.

– has established a process to ensure that the principles and the
minimum requirements of the policy will be followed within his/her

respective unit.

_________________________________

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APPENDIX 1 INTERNAL COMMUNICATION

Purpose

The purpose of Swedish Match’s internal communication is to contribute to the

Group’s business objectives. It shall provide open and explanatory information

aimed at informing employees of the Company’s development, enhancing their

knowledge of values, business objectives and strategies in order to strengthen their

commitment, motivation, loyalty and sense of responsibility. Another important aim

is to facilitate the recruitment of new employees by enabling Swedish Match’s

employees to act as effective “ambassadors” for the Group.

Target groups

All employees, including senior executives and managers

Principles

Internal communication at Swedish Match shall contribute to the Group’s business

objectives. To this end, internal communication shall:
maintain a high quality
maintain continuity
utilize benchmarking – in other words, point to successful methods that can

provide inspiration and examples of excellence in the organization’s various

operations
encourage two way dialogue at all levels and develop possibilities for employees

to give feedback and to be part of an open, inclusive communications climate.

Responsibility

The operating unit heads (Presidents or COOs), in consultation with the SVP of

Corporate Communications and Sustainability, bear the primary responsibility for

creating an open communication culture that conforms to the Swedish Match core

values and Code of Conduct and has the necessary organization and resources for

distributing relevant information to employees. Corporate Communications and

Sustainability is responsible for coordinating internal information.

Channels

In addition to daily contact between managers and employees, the main channels for

distributing internal information are:
The main and foremost information channel is the Intranet, containing current

and continuously updated company information, external and internal news,

articles and policies, among other items
In person communication, such as group meetings, which are a very efficient

communications channel, and should be used whenever practicable, taking into

account logistical and environmental considerations
Newsletters and information to ensure cascading of information concerning

Group decisions and events
The corporate website, swedishmatch.com, containing important information

about the Group/Company

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APPENDIX 2 EXTERNAL COMMUNICATION

Swedish Match’s external communications have a large number of disparate target

groups. Of these, the capital markets and the media occupy a special position due to

the laws, regulations and standards that apply as a result of Swedish Match being

listed on NASDAQ OMX Stockholm. It is of special importance that Swedish

Match’s information and employees comply with these laws, regulations and

standards
2
.

1. Investor Relations

Purpose

To keep the capital markets continuously informed about Swedish Match’s position,

operations and development. The information provided by the Swedish Match

Investor Relations department also serves to broaden knowledge of and interest in

the Company and thereby improve liquidity in trading of the Company’s share,

reduce risk from information deficits, and facilitate the raising of capital in the

equity and debt markets.

Target groups

Target groups are current and potential legal and physical shareholders, current and

potential creditors, stockbrokers, financial analysts, financial and market journalists,

and NASDAQ OMX Stockholm.

Principles

The information disclosed by Swedish Match concerning its financial position and

development shall at least meet the minimum requirements prescribed for companies

listed on NASDAQ OMX Stockholm. The following principles apply:

Reliability – All information to the capital markets shall be factual and correct,

and must not be misleading in any way
Speed – All information shall be issued as quickly as possible, so that Swedish

Match always retains the initiative to issue first-hand news
Simultaneity – All information to the markets shall be conveyed to all financial

target groups simultaneously
Long-term, consistent and proactive – Swedish Match shall always give correct

and pertinent information to the markets in order, as far as possible, to avoid

surprises that could reduce market trust in Swedish Match and have a negative

impact on the Group’s capital market relations. Information must be fact-based

and not speculative. Accordingly, Swedish Match shall not comment on rumors

and speculation, unless there are serious negative effects of not commenting

Swedish Match invites all representatives in the financial markets, including

financial journalists, to participate in a telephone conference on the same day as

2
See Appendix 4, Stock market information

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interim reports are published. Following the publication of such reports, Swedish

Match participates in group meetings and one-to-one meetings with investors.

Swedish Match also meets analysts, fund managers and investors on a continuous

basis to create a better understanding of Swedish Match and assist these

representatives in making an accurate analysis of the Group.

Silent period

The nearer a reporting date approaches, the greater the interest in obtaining

information and the greater the risk of leaks. To reduce this risk, Swedish Match

observes a “silent period” beginning 30 days prior to publication of a year-end or

interim report. During this period, representatives of Swedish Match refrain from

answering questions or commenting on financial developments, citing the silent

period as the reason. Special care must be taken in contacts with investors, analysts

and journalists. However, the silent period should not be interpreted as meaning it is

forbidden to give any financial information at all. General clarification of facts and

information about circumstances that are already known are permitted, but all

future-oriented or economic and financial information that could be linked to the

forthcoming quarterly report is forbidden.

The silent period does not affect the interpretation of the disclosure rules in the Rule

Book for Issuers issued by NASDAQ OMX Stockholm (the “Rule Book”), the rules

of which shall always be followed.

When analysts request and receive comments on analyses and reports, only direct

factual errors may be pointed out. In contacts with analysts, it can be regarded as

permissible, for example, to enlarge on information provided previously, give

reminders of information provided previously, correct misunderstandings,

miscalculations and obvious logical errors, and provide industry statistics. No

comments may be given regarding profit forecasts. In regard to contacts with

analysts, see also Appendix 4, Stock market information.

Disclosure Committee

In Swedish Match has established a reporting committee to assure quality in all

financial reporting. The committee’s scrutiny covers, among other items, all external

financial information in the form of interim reports and year-end reports, annual

reports, and all press releases issued by the Group’s head office, or if the

information is of a price-sensitive nature. Members of the Disclosure Committee are

the heads of Corporate Communications and Sustainability, Group Reporting and

Tax, Group Business Control, and Group Legal Affairs (chairman).

Investor Relations activities are dealt with exclusively at Group level. The CFO and

SVP Corporate Communications and Sustainability bear overall responsibility for

Investor Relations. The SVP Corporate Communications and Sustainability is

responsible globally for all ongoing contacts with analysts, fund managers and other

financial market representatives. The SVP Corporate Communications and

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Sustainability shall be informed immediately about all contacts from financial

market representatives with persons within the Group.

In all financial communications, the CEO in the first instance and the CFO in the

second instance is the principal spokesperson for Swedish Match. In addition, all

communications with Investor Relations target groups are organized and conducted

through the head of Corporate Communications and Sustainability, who also

participates in communications with the financial markets in regard to pertinent

issues.

Corporate Communications and Sustainability and Group Finance together with the

CFO, are responsible for producing and distributing all financial information,

including, among other items, annual reports, quarterly reports and other financial

information as required by NASDAQ OMX Stockholm, and Swedish regulations

and standards.

Channels

These include the Corporate website, annual report, interim reports, press releases

and presentation materials, as well as meetings with analysts and the press,

conference calls, investor meetings and individual contacts with target groups.

2. Media relations

Purpose

As the distributors of and commentators on of all general information issued by

Swedish Match, the media constitute the single most important external target

group. Since the media are among the most important sources of information about

the Group for customers, shareholders and employees and in the rest of the capital

market, it is essential that information provided to the media by Swedish Match

creates awareness about the Group and its operations in such a manner that the

media convey an objective, pertinent and accurate picture of Swedish Match.

Target groups

Journalists in the press, radio, television and online media.

Principles

Representatives of Swedish Match must be familiar with and respect the media’s

working conditions and integrity.

Swedish Match’s media relations shall be characterized by openness, objectivity,

speed, clarity, a long-term approach, continuity and high ethical standards. To be of

value to the company, relations with the media must be long-term and based on

mutual relationships. Due to competition and the thirst for news within the media,

articles and radio and television features are sometimes based on rumors and

incomplete information. Consequently, all contacts with the media must respect the

restrictions that apply to listed companies. The basic rule is that all important

information must be released simultaneously and with equivalent content.

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Responsibility

The head of Corporate Communications and Sustainability has overall responsibility

for all media contacts. For local media issues, contacts are maintained by the

operating units. All responsible managers must be fully familiar with the media’s

ethical guidelines.

Channels

The Corporate website, annual report, interim reports, press releases, presentation

materials, meetings with analysts and the press, conference calls, and individual

contacts with journalists.

3. Other external information and social information

Purpose

To increase people’s knowledge about Swedish Match and its operations, focusing

on the Company’s role as a responsible tobacco company in the local communities

where the Group’s plants are located, with the aim of strengthening people’s

confidence in Swedish Match and its brands and enhancing the Group’s recruitment

possibilities.

Target groups

Customers, suppliers, employees and their families, potential employees, politicians,

authorities, relevant organizations and the general public.

Principles

Swedish Match’s contacts with all external target groups are to be characterized by

continuity and a systematic, long-term approach. To achieve this, all external

information must meet the basic criteria of openness, speed, objectivity and clarity.

Responsibility

Corporate Communications and Sustainability, in cooperation with relevant

managers at the Group, regional and local levels.

Channels

The Corporate website, the annual report, interim reports, press releases,

presentation materials, press conferences, individual contacts within target groups,

and organized meetings and events.

4. Guidelines for sponsorship activities

Proposals concerning Group wide sponsorship activities must be submitted to and

approved by the head of Corporate Communications and Sustainability or another

member of Group management. Proposals shall be evaluated based on legality,

image building potential and commercial value to the Company.

5. Communication and marketing of brands
It is important to consider the effects of brand marketing, promotional activities and

product samples on the image of Swedish Match, taking into account the applicable

regulations and legislation. Operating unit heads (Presidents/COOs) must carefully

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scrutinize these programs against the background of the Group’s Tobacco Policy

and Code of Conduct and the risk of negative reactions from consumers.

Within the statutory and regulatory framework, information about our brands and

products may also be presented in a responsible manner on “brand websites.” All

such brand websites must be approved by the head of Corporate Communications

and Sustainability, with content the responsibility of the appropriate operating unit

head. For detailed information, refer to Swedish Match’s Group Web

Communication Policy.

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APPENDIX 3 CORPORATE WEBSITE

There shall be only one Swedish Match Corporate website:

www.swedishmatch.com. As a principal source of information about the Group, the

website plays a strategic role in the Company’s communication program. The

Group’s website should be a high-quality central medium serving both internal and

external visitors.

The Rule Book for Issuers issued by NASDAQ OMX Stockholm is a minimum

standard for Swedish Match’s website. Furthermore, the Company’s is following the

guidelines and recommendations in the Swedish Code of Corporate Governance

(koden för bolagsstyrning). It is Swedish Match’s aim that all important information

should be published on the website with the minimum possible delay.

The Corporate website shall be systematic in its structure, easy to navigate in and set

up in such a way that different stakeholder groups can easily find the information

they are seeking.

The corporate website shall contain:
a general description of the company,
financial information,
all significant external information documents, such as press releases, annual

reports, financial reports, presentations from meetings/telephone conferences

with analysts as well as policies. Information should be stored in archive since

1996 when Swedish Match was publicly listed,
share page with information about trading in Swedish Match shares and share-

performance diagrams,
a separate section devoted to corporate governance matters, such as the

Company’s current articles of association and the most recent governance report

as well as updated information as regards members of the board, the chief

executive officer and the auditor and a detailed account of each outstanding

share- and share-price-related incentive scheme,
agendas and timetable for publication of all financial information and for

shareholder meetings, meetings with analysts and telephone conferences,
meetings with analysts that can be directly broadcast via the web and are

recorded and stored on the website,
facility for contacting SVP Corporate Communications and Sustainability via

e-mail,
frequently asked questions (FAQ),
contact function,
a site map.

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APPENDIX 4 STOCK MARKET INFORMATION

As a company listed on NASDAQ OMX Stockholm, Swedish Match disclosure is

governed by the NASDAQ OMX Rule Book for Issuers
3
(the “Rule Book”).

According to the Rule Book a listed company shall ensure that all market

participants have simultaneous access to any price sensitive information about the

company. The Company is also required to ensure that the information is treated

confidentially and that no unauthorized party is given such information prior to

public disclosure. As a consequence of the foregoing, price sensitive information

may not be disclosed to analysts, journalists, or any other parties, either individually

or in groups, unless such information is simultaneously made public to the market.

The Rule Book includes information about what kind of information that must be

published by the Company on a regular basis and also provides guidance and

examples on what kind of information that typically is to be considered as price

sensitive.

The quality of stock market information shall be assured through the reporting and

control process defined in Swedish Match’s policies and guidelines and applied by

the Group’s Disclosure Committee. This process shall adhere to all the applicable

legislation, regulations and standards for Swedish listed companies, including but

not limited to the Rule Book.

All stock market information shall be examined and approved by the Disclosure

Committee prior to distribution.

Publication

Swedish Match publishes information by immediately distributing a press release in

accordance with the Rule Book, meaning directly after a decision has been made or

an event has become known to the Company. If a decision or event is made or has

occurred after the end of the working day and the decision or event could reasonably

be expected to affect the share price, the information must be published in due time

prior to opening of NASDAQ OMX Stockholm the next day.

Selective information release
As an exception, and only in special cases, unpublished information that could affect

the share price may be passed on to persons outside the Company (selective

information) without being published simultaneously. This applies to situations in

which it is of crucial importance to the Company to be able to selectively release

certain information. The Rule Book provides examples on situations where a release

of selective information may be allowed.

3
The most recent version is to be found at www.nasdaqomx.com

http://www.nasdaqomx.com/

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Swedish Match’s responsible representative should make clear to recipients of

selective information that they must treat such information as confidential and that

they have, by receiving the information, become “insiders” and are thus forbidden

by law from utilizing the information for their own or any other person’s gain.

In addition, the company representative who gives out selective information should

keep a record of who has been given access to what information, when this occurred

and what the information pertained to. Special confidentiality agreements between

the parties should be drawn up to protect selective information. In addition, the

Company must always comply with the obligation to compile and keep updated a

list of persons (a so called “Log Book”) who work for the Company, due to

employment or other engagement, and possess insider information about the

Company.

Who decides what information is price-sensitive?
Within Swedish Match, the CEO bears ultimate responsibility for assessing what

factors are price-sensitive and ensuring that information is released as prescribed in

the Rule Book.

The CEO has delegated the task of assessing, on an ongoing basis, what factors are

price-sensitive to the head of Corporate Communications and Sustainability, subject

to consultation with the head of Legal Affairs and with the CFO in regard to

financial matters. The consequence of this division of responsibility is that:

other senior executives or the Presidents/COOs of operating units do not have the

right to make statements concerning overall corporate issues – the point of this being

to minimize the risk of potentially price-sensitive information being disseminated

without the CEO’s knowledge.

Subsidiaries may not issue press releases regarding Group wide or Corporate issues

without first consulting Group Corporate Communications and Sustainability.

Information leaks

Information leaks and rumors can cause significant damage in the form of costly

disruptions, negative publicity, or even lost business and an undermining of

confidence in Swedish Match. Our policy is not to comment, which means that our

response is: “Our policy is not to comment on speculation and rumors.” Any

employee who becomes aware of rumors or leaked information shall immediately

inform Group Corporate Communications and Sustainability.

The head of Group Corporate Communications and Sustainability will decide, in

consultation with the CEO and Legal Affairs, whether the rumor is serious and could

damage Swedish Match. In certain cases, the CEO should be informed. Swedish

Match will then consider whether to issue a clarification as soon as possible via a

press release.

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In situations where decisions are being planned that are of great importance for the

company, such as bid situations, Swedish Match shall maintain a high state of

preparedness for issuing information at short notice – for example, by having

prepared press releases and prearranged contacts with the relevant decision-makers.

In this way, any damage caused by leaked information can be reduced.

Contacts with analysts

Analysts are an important group with a significant influence on the pricing of the

Swedish Match share as a result of the analyses they distribute, primarily to

institutional investors. Financial journalists working for media with national and

international coverage are placed on the same footing as analysts in the applicable

sections of the guidelines for contacts with analysts.

The CFO and the SVP Corporate Communications and Sustainability jointly bear

the principal responsibility for developing contacts with analysts and investors.

Ongoing contacts are handled by the SVP Corporate Communications and

Sustainability, or an Investor Relations representative designated by the SVP, who is

responsible for building up long-term and positive relations with analysts and giving

them professional service in accordance with laws, regulations and standards. The

SVP Corporate Communications and Sustainability/Investor Relations

representative must adhere to all parts of the Rule Book and not provide price

sensitive or selective information. This person or persons shall engage in proactive

contacts and give feedback to the CEO, the CFO and, if applicable the head of

Corporate Communications and Sustainability as part of the dialog with stock

market representatives. The Investor Relations representative (generally the SVP of

Corporate Communications and Sustainability) shall always be informed about other

employees’ contacts with analysts and shareholders.

Analysts often use the opportunity to contact companies in order to obtain

unpublished information to supplement their picture of the company, thereby

enabling them to gain a better understanding of the conditions under which a

company operates. However, this must not lead to a situation where Swedish Match

selectively releases price-sensitive information. This would not only be in breach of

the Rule Book but would also place the analyst concerned in a difficult position

involving a risk of committing a violation of the Market Abuse Act which forbids

persons who have had access to unpublished information that “is likely to materially

affect” the share price from conducting share transactions or advising others to

conduct share transactions.

It is thus permissible to selectively release information that is not price-sensitive.

But Swedish Match shall not release such information merely to satisfy an analyst. It

is of course acceptable to politely but firmly direct and refer the analyst to the

Company’s normal published information.

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In contacts with analysts it is, for example, considered acceptable to:
explain and clarify previously published information,
give a reminder of previously released information,
correct misunderstandings, miscalculations and obvious logical errors, and
provide industry statistics.

If Swedish Match is simultaneously issuing a press release, it is permissible to

supply price-sensitive information stated in the press release at a meeting with

analysts, whether it is a normal meeting or a teleconference. In the event that price-

sensitive information is inadvertently released in such a meeting – when responding

to an unexpected question for example – a press release shall immediately be issued

giving the disclosed information.

If one analyst has received certain information, Swedish Match cannot refuse to give

another analyst or a journalist the same information. This should therefore be a

factor in assessing whether to release information. Swedish Match shall be prepared

to release the same information to the media.

It is absolutely forbidden to give analysts or journalists advance information about a

coming news item, even if guarantee not to disclose it prior to publication.

There is no such thing as “off the record.” All information given to a journalist must

be regarded as public.

Swedish Match invites the media to conferences with analysts to reduce the risk of

such meetings being viewed with suspicion. The media participate on the same

terms as other participants.

Analysts shall be treated fairly and all be given access to the same information,

whether they represent a small or large shareholder or firm of analysts.

Swedish Match does not distribute analysts’ reports outside the circle concerned

within the Company, since there is a risk that this could be interpreted to the effect

that the Company sanctions the content of the report and is thus providing

information selectively. Interested parties shall instead be referred to the respective

firm of analysts. Swedish Match states on its website which analysts monitor the

Company.

Comments on analysts’ profit forecasts

Swedish Match does not issue detailed forecasts. In the annual report and interim

reports and at meetings with analysts, however, management gives its views on

certain factors in the business environment and in the Company’s performance that

make it easier for the stock market to form an impression of Swedish Match’s sales

and earnings trends. The Group has a responsibility to provide information about

changes affecting such factors in quarterly reports and in its comments on

performance during the preceding quarter. If the changes are of major significance,

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they shall be reported in accordance with the requirements in the Rule Book

regarding press releases that must also go to NASDAQ OMX Stockholm.

It is not appropriate to actively (in-person meetings or telephone calls) gather

information about analysts’ forecast assumptions. Information gathering from

published analysts’ reports or from aggregated data from professional companies

such as SME Direkt is accepted. Swedish Match should be careful not to directly or

indirectly express any opinion about individual analysts’ forecasts. If an analyst is

seeking information about “consensus” forecasts for Swedish Match, he or she

should be referred to the companies that supply such information, such as SME

Direkt or Thomson Reuters.

If the Swedish Match management thinks that the market’s forecasts are unrealistic,

the Investor Relations function shall endeavor to find out why the market forecasts

are at the wrong level by studying the analysts’ reports. If the reason is that the

market has misunderstood the information supplied by the Company, a correction

should be issued immediately, via a press release in more serious instances, while in

less serious cases the correction can be made in the next financial report. In such

instances, Swedish Match should also review the content and structure of its reports

to avoid a repetition of such a misunderstanding. On the other hand, it is not

permissible for the Company to contact individual analysts who deviate from the

market’s assessments, since this could be construed as providing information

selectively.

Meetings with investors and analysts

The capital market representatives are interested in receiving fast, pertinent and

accurate information about Swedish Match’s operations. This is a prerequisite for

the analysts to be able to give continuous valuations of the share and assess the

future prospects of the Group.

Contacts with analysts shall be professionally correct and of a high quality. It is in

Swedish Match’s interests to always retain the initiative in regard to price-sensitive

information and to be able to publish such information in a well-organized manner

in accordance with the Rule Book.

For this reason, Swedish Match organizes teleconferences on the day of publication

of year-end or interim reports, with analysts and the media. Following the release of

a financial report, investor meetings can be arranged, and when necessary organizes

capital market meetings to permit a more detailed review of developments in the

business environment and within the Group. The CEO and the CFO also visit a

number of analysts and investors during the year to give additional presentations.

These meetings give the CEO the opportunity to present and describe Swedish

Match before a group of serious professional company analysts and investors, so

that the Group’s development is well communicated and perceived by the capital

market representatives.

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Responsibility for organizing these meetings and contacts rests with Investor

Relations.

Prior to such meetings, the CEO and the CFO shall formulate a clear communication

strategy for what they wish to convey, so that they will not be provoked into

releasing more information than they had intended. Thorough preparations should be

made for meetings with analysts and investors. Presentation materials should be of

high quality and a rehearsal should be conducted.

All meetings and contacts with analysts and investors shall be documented.

As in all other situations where Swedish Match is reporting on its operations, the

general principle applies that all information about price-sensitive events and

circumstances shall be disseminated simultaneously and equitably to all the

representatives in the market.

The financial media shall be invited to telephone conferences, breakfast meetings

and capital market days.

One-on-one meetings

One-on-one meetings involve a company representative meeting a single analyst,

investor or financial journalist. Swedish Match’s basic rule is that such meetings

shall be handled by the Investor Relations team and include any or all of the

following: the CEO, the CFO, the SVP of Corporate Communications and

Sustainability, or or a person specifically authorized for such a type of meeting by

the CEO.