Policy on Communication and Contact with Shareholders, Investors, and Proxy Advisors and on the Disclosure of Economic-Financial, Non-Financial, and Corporate Information
Our aim is to define and establish the general principles and criteria that govern the communication of economic and financial, non-financial, and corporate information by the channels considered appropriate, and in particular the contact with shareholders, investors, and proxy advisors. It focuses especially on the points of view of shareholders and significant investors who are not represented on the Board of Directors. The foregoing is without prejudice to the legal obligations to disseminate inside information, other relevant information, and other regulated information applicable to the Company.
The Board of Directors is responsible for top-level management and supervision of information provided to the stock market, investors, and other interest groups, ensuring the highest disclosure and quality, in accordance with the following general principles:
These principles will be applied to information and communication from the Company to its stakeholders, such as shareholders, institutional investors, financial institutions that act as intermediaries, agents, and depositories of the Company's shares or debts instruments, financial and non-financial analysts, regulatory and supervisory bodies, credit rating agencies, information agencies, proxy advisors, the media and does of kind.
Notwithstanding the principles of equal treatment and non-discrimination, the Company may adapt the general and special channels for information and communication with the stock market, investors, and other stakeholders, depending on the different target groups.
All the aforementioned, in compliance with current regulations on the treatment of privileged information and other relevant information, shareholder relations, and communication with the stock market. These rules are all set out in the Board of Directors Regulation, the Internal Conduct Regulation regarding the Securities Market, the Code on Ethics and Conduct, and the internal norms on classification of information in the stock markets and their regulatory entities.
General information and communication channels
The first general channel that the Company uses to provide information to shareholders, investors, and markets in general, is the regulatory body of the Spanish Stock Market, the Comisión Nacional del Mercado de Valores, (CNMV) – which receives all information that, in accordance with current legislation, is considered privileged or relevant, periodic financial and non-financial information and corporate information established by law. It also uses channels established by foreign supervisory bodies and authorities when appropriate. The information sent to the CNMV is immediately disseminated and made public through publication on its website.
The Company will promote its corporate website (www.repsol.com) as an information channel for shareholders, investors, and other stakeholders. Any economic and financial, non-financial and corporate information that may be of interest will be published on the website, with the advantage that the information can be published immediately and can be accessed afterwards. This prioritizes transparency as the value that defines the Company's relationships with markets and with the general public. All communications of inside information or other relevant information made by the Company, as well as periodic financial and non-financial information and corporate information established by law, shall be simultaneously published on the corporate website.
The Company shall have a specific communication area, responsible to manage, among others, the relationship with the media and to prepare the press announcements with the areas affected, maintaining the coherence and alignment between the announcements issued by the Company in any of its supports and channels.
The Company is aware that new information technologies have a relevant impact and influence on social activity and on its relations with shareholders, investors and other stakeholders. For this reason, and in order to contribute to the maximization of the dissemination of information, the Company may use, in addition and complementary to the above means of communication, social networks of relevant acceptation, distribution, presence and monitoring, to communicate economic-financial, non-financial and corporate information, whenever the requirements established in the current regulations on the communication of privileged information and other relevant information, as well as the other internal rules of the Company, are complied with.
Annual General Meeting (only available in Spanish)
The Board of Directors shall promote the informed and responsible participation of the shareholders in the General Shareholders' Meeting, adopting the appropriate measures to facilitate the exercise by the General Shareholders' Meeting of its functions. To this end, the Company shall make available to its shareholders, prior to the General Meeting, such additional channels of communication as may be appropriate from time to time, such as the electronic shareholders' forum or such others as may be established, as well as such information as may be legally required or, even if not legally required, may be of interest to them and can reasonably be provided. It shall also respond with the greatest diligence to requests for information and questions posed by shareholders prior to or on the occasion of the General Meeting.
The Company may use the services of agencies, entities and financial intermediaries to better distribute information to its shareholders and Institutional Investors.
For its part, the general secretary's office, with the support of the investor relations area, shall be responsible for liaising with proxy advisors, responding to their queries in relation to the proposed resolutions to be submitted to the General Meeting of Shareholders and providing them with the clarifications deemed appropriate.
This policy was approved by the Board of Directors of Repsol, S.A. on December 16th, 2015, and subsequently amended on February 17th, 2021.