Policy: Speaking to the Media

Title:Policy on Speaking to the Media
Policy Owner:Corporate Office; Communications
Applies to:All HomeTrustee and Red Hill Ventures Employees
Effective Date:July 10, 2019
Summary:Defines the protocol for speaking to the news media regarding matters related to the company, employees and/or residents.

Purpose of Policy:

HomeTrustee and/or Red Hill Ventures needs to be able to communicate accurately, effectively and consistently with a variety of diverse audiences including the media. The purpose of this policy is to define the protocol for employees communication with external parties and define who may speak on behalf of Home Trustee, Inc. and/or Red HillVentures to the news media regarding incidences that occur on the property. Communications with the news media are managed by the Corporate Office for marketing, publications and other public relations functions. This ensures a singular and consistent voice and message.

Corporate Office is the primary and official contact for news media on matters involving our properties. employees and/or residents. Corporate Office is responsible for initiating, developing and maintaining effective, productive and beneficial relations with the news media in coordinating official company comment on all matters regarding the Company. This includes both proactive interaction and responses to requests.

  1. Definitions of News

    News Media means entities or mechanisms for delivering news to the general public or to a targeted audience. News Media outlets include but are not limited to: newspapers; magazines or journals; television or radio stations or networks; and online media, including Social Media.

  2. Guidelines for Commenting to the Media

    All inquiries seeking information and/or comment from the news media should be directed to the appropriate Company spokesperson. It is suggested to get the name(s) and contact information of the individual(s) seeking information and/or comment and provide the appropriate Company spokesperson with that information rather than provide the inquirer with the contact information for a specific Company Spokesperson. This manner of communication ensures the proper management of contact within our Company.

    • Company is committed to non-selective, fair disclosure of information about The Company without advantage or disadvantage to any participant

    • The Company will voluntarily disclose any non-material information, which is not the subject of a confidentiality agreement and determined by senior management;

    • All disclosures to the media will be communicated by an authorized Media Relations Officer or designate; Director of Operations or President

    • All disclosures to the financial community, including investment analysts, brokers and current or potential investors will be communicated by the CEO, CFO, and Investor Relations or their designate(s)

    • The External Communications Policy applies to all the Company employees and, with respect to their reference to the Company, all subsidiaries and associates

    • Management will be responsible for ensuring that this policy and related procedures are communicated and followed consistently in their operations

    • Non-compliance with this policy may damage the Company’s reputation and/or cause the Company and/or its shareholders to be prejudiced and to suffer damages and/or losses

    • As with all ofThe Company’s policies any non-compliance will be treated as serious and will result in disciplinary action and could give rise to civil and/or criminal liability on the part of the employee. It is the responsibility of all employees to familiarize themselves with this policy

An appropriate response to an incident would be:

Home Trustee is fully cooperating with an ongoing (police/fire/agency) investigation and am unable to comment at this time. However, I’ll be happy to take your information, so that the appropriate person within our company can contact you, once all of the information and/or facts are received by all parties involved.

Personal Speech:

Nothing in this policy is intended to restrict the freedom of employees to engage in their personal involvement in community activities. Nothing in this policy is intended to affect individual employees’ rights to express personal opinions on Company or non-Company actions and policies. Nothing in this policy is intended to restrict employees from commenting on matters of public concern implicating an employer’s official dishonesty, deliberately unconstitutional action, other serious wrongdoing or threats to health and safety. When speaking or writing as a citizen, an employee should be accurate, should exercise appropriate restraint, should show respect for the opinions of others and should make every effort to indicate that he/she does not speak for the Company.

The Company reaffirms its continuing commitment to the right to freedom of speech protected by the United States Constitution.