12 Trading blackout periods

Swisscom defines ordinary and, if need be, extraordinary trading blackout periods for trading in Swisscom securities by the Board of Directors, Group Executive Board and employees (hereinafter collectively referred to as ‘employees’). This is the responsibility of the internal clearing unit, which is made up of the CFO, the Head of Investor Relations and a specialist from Group Legal Services. The four ordinary trading blackout periods prior to the announcement of the company’s figures are aimed at all employees who become aware of the unpublished company figures. The clearing unit maintains a corre­spond­ing insider list. Unless the clearing unit issues instructions to the contrary, the ordinary blackout periods last around four weeks and end 24 hours after the com­pany figures are made public. The clearing unit informs the individuals affected of upcoming trading blackout periods in an e-mail sent out every year before the start of each trading blackout period. The details are also available on the intranet.

Extraordinary trading blackout periods are imposed by the clearing unit on an ad-hoc basis if other unpublished price-sensitive in­for­ma­tion arises. These apply to individuals with the relevant insider knowl­edge. The clearing unit maintains cor­re­spond­ing insider lists. The trading blackout periods last for the period specified by the clearing unit. They end 24 hours after the price-sensitive in­for­ma­tion is made public or when specified by the clearing unit. The clearing unit informs employees of any trading blackout periods imposed by email.

The clearing unit makes decisions on any exceptions to the ordinary and extraordinary trading blackout periods on a case-by-case basis in the event of special circums­tances. No exceptions were granted in the year under review.