Corporate Disclosure Policy

Purpose

The Corporate Disclosure Policy sets out the Group’s approach to the timely, accurate and accessible disclosure of material information. The Policy supports compliance with the Capital Markets Authority Code of Corporate Governance Practices, the Capital Markets Public Offers, Listings and Disclosures Regulations, 2023, Nairobi Securities Exchange obligations and other applicable disclosure requirements, while reinforcing transparency, accountability and investor confidence.

Scope

The Policy applies to directors, management, employees and relevant functions involved in identifying, handling, approving, releasing or retaining material information. It covers periodic and continuous disclosures, including financial results, board changes, dividends, corporate actions and other material information disclosed to regulators, shareholders, investors and the market.

Key Provisions

1. Disclosure Principles: The Group’s disclosures are guided by timeliness, accuracy, materiality and accessibility to support fair, transparent and informed communication with stakeholders.
2. Material Information: The Group discloses material information promptly, including financial results, board changes, dividends and other matters requiring regulatory or market disclosure.
3. Periodic and Continuous Disclosures: The Policy covers scheduled disclosures, including financial and annual reporting, as well as continuous disclosures arising from material events.
4. Disclosure Process: Material information is identified, verified, approved, released through appropriate channels and retained for record-keeping and accountability.
5. Governance and Review: The Board oversees the disclosure framework, supported by management processes, review mechanisms and appropriate assurance over disclosure practices.

Roles & Responsibilities

Board of Directors: Provides overall oversight of corporate disclosure and ensures that material information is disclosed in a timely, accurate and compliant manner, in line with regulatory obligations and good governance practice.

Management: Implements the Policy through approved disclosure processes, including identification, verification, approval, release and retention of material information. Management also coordinates regulatory engagement, supports disclosure controls and escalates material disclosure matters through the appropriate governance channels.

Why It Matters

• Promotes timely, accurate and transparent market communication.
• Helps shareholders, investors and other stakeholders make informed decisions.
• Reduces the risk of selective, delayed or inaccurate disclosure.
• Supports compliance with regulations and other applicable disclosure obligations.
• Strengthens accountability, market confidence and corporate governance discipline.