12 Trading blackout periods

To prevent insider trading by its Board of Directors, the Group Executive Committee or employees, Swisscom has defined measures, including ordinary and extraordinary trading blackout periods. Setting trading blackout periods is the responsibility of the internal clearing unit, which is made up of the Group CFO, the Head of Investor Relations and a specialist from the Legal division. The four ordinary trading blackout periods prior to the announcement of the company’s figures apply to all employees and executives (insiders) who become aware of the unpublished company figures, for which the clearing unit maintains an insider list. Unless otherwise advised, the ordinary blackout period lasts for around four weeks and ends 24 hours after the company figures are made public. The clearing unit informs insiders of upcoming trading blackout periods by e-mail, and details are also available on the intranet.

The clearing unit imposes extraordinary trading blackout periods on a list of individuals with relevant insider knowledge on an ad-hoc basis as other unpublished price-sensitive information arises. The clearing unit maintains corresponding insider lists. The extraordinary trading blackout period ends 24 hours after the price-sensitive information is made public or as specified by the clearing unit. The clearing unit informs employees of trading blackout periods by e-mail.

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