Archive for the ‘IR 2.0 – Web & social media’ Category

IR nightmare: leaking earnings

August 2, 2011

As the Q2 reporting season winds down, a nightmare scenario for investor relations professionals comes to mind: accidentally leaking your company’s earnings release or M&A announcement by inadvertently posting it online. Such a leak spreads easily into a widespread spill into social or traditional media.

Can’t happen? Well, it does. A panel discussion at the NIRI 2011 Annual Conference in June was all about warning IR people of this potential mishap. Two folks from Microsoft, IR manager Dennie Kimbrough and IT manager Josh Bailey, courageously provided the red meat of the NIRI panel discussion called “Keep a Lid on It: How to Guard Against Leaks, and What to Do if One Happens.”

Most importantly for all of us in investor relations, the Microsoft staffers shared lessons learned on how to guard against similar leaks at our companies.

The software giant is one of a handful of companies – Walt Disney, NetApp and Transocean are others – recently tripped up by the interplay of humans and technology, causing the inadvertent, early and selective release of earnings.

For MSFT, it happened on January 27, 2011. According to Kimbrough, the first word of a problem came about 12:35 p.m. Pacific time, an hour before the market would close. A Reuters reporter called to confirm an online report of the software giant’s Q2 earnings – not due out until after the close. Not the media call you want to get.

It seems MSFT’s 77-cent earnings per share figure was already out on StockTwits, through the work of Selerity, a “low-latency news aggregator.” For us non-techies, that means Selerity uses web crawler programs to snoop around continually for information on web pages that might move stocks – and move the data quickly to its clients, who are hedge funds, banks and prop traders.

What Selerity’s crawlers found was a page where someone at Microsoft posted Q2 earnings data on what they assumed was a secure “staging” page, but actually was a live web page. “It was just a simple human error,” Kimbrough said.

There was no link to it, as an official news release gets when posted to a website, but crawlers don’t need a link. Kimbrough said MSFT put its earning data up on the blind (but public) web page at 11:23 a.m., and Selerity’s crawler found it six minutes later. Selerity sent the numbers right out to its clients – and broadcast MSFT’s 77-cent EPS on StockTwits at 12:50, a full 70 minutes before the close.

Bailey, the Microsoft IT guy, explained three kinds of web crawlers: Those used by search engines “play nice” with web administrators in handling nonpublic files. Others scrape email addresses and phone numbers from thousands of websites to enable marketers to spam us. A third, scarier group of crawlers search for not-yet-public pages, systematically guessing URLs that might provide interesting data (something like “…/earnings/Q2/press release.html”).

The problem isn’t brand new. Another panelist, Andy Backman (a former IRO and now CEO of InVisionIR) recalled an encounter 10 years ago when a reporter guessed the URL for his company’s second-quarter earnings release – and reported the numbers an hour and a half before the release was due out.

Of course, the damage-control step to take if a leak of this sort happens is to issue the darn news release – get it out fast! Microsoft posted a brief statement to its corporate blog immediately after the reporter’s call and had the full earnings announcement up by 12:55 Pacific time, about 20 minutes after the reporter’s call.

But prevention is the real need.

And prevention is where IROs can play an important role by taking precautionary steps as part of the team that develops earnings and M&A announcements:

  • Keep online staging areas secure to prevent public posting of earnings and similar announcements. “The only way to protect yourself against web crawlers is to keep your files on your side of the firewall,” Bailey says. Both in-house staffers and third-party service providers like lawyers, CPAs and newswires need to have strict procedures in place. The IRO needs to check.
  • Don’t allow anyone to leave drafts lying around on a printer or desk. This is the old-fashioned leak, allowing non-confidential employees or even members of the public who pass by to see nonpublic information sitting out in the open. “Shred everything. Lock it away,” Backman advises.
  • Demand better code names for M&A projects or offerings. Lawyers and I-bankers love to create code names. And they’re fun – we all get a sense of adventure working on a hush-hush project called “Operation Pegasus.” Trouble is, Backman notes, code names are almost always picked because they point to the real name. We’re making a bid for Procter & Gamble, so we call it Operation Pegasus. Sometimes namers use a double entendre (the acquisition of Energizer might be “Project Bunny”). Backman suggests: Pick a code name that has nothing to do with the target company – a code name.

In many respects, IR professionals need to be a little paranoid. For most of us, Q2 reporting is finished (my excuse for not posting in July), but security of financial information is a process issue we can start working on now for next quarter.

As gatekeepers of material information, IR people need to work with colleagues in finance and IT to ensure that “Top Secret” remains so right up until our broad dissemination to the market.

© 2011 Johnson Strategic Communications Inc.

Websites – not the only channel

May 27, 2010

Nearly two years after the SEC issued guidance on use of company websites for disclosure, a survey of investor relations professionals by the National Investor Relations Institute (NIRI) reports few have changed their web disclosure practices.

In August 2008 the SEC – before the near-meltdown of our entire financial system captured its full attention – issued an interpretive release on use of web-based media to fulfill Regulation FD disclosure responsibilities. (Read SEC guidance here.)

The essence of the SEC guidance, carrying out then-Chairman Chris Cox’s agenda to bring disclosure methods into the 21st Century, was to let companies know they can establish their websites as the place for investors to find material news. That set off speculation (and some advocacy) that companies would stop issuing press releases and possibly abandon other channels of disclosure. It hasn’t happened.

According to NIRI’s survey of about 200 senior IR people, 93% have not changed the role of their websites – and only 7% have – since the SEC guidance. NIRI adds, “the 7% who did make changes … are using more channels, not fewer.”

To be sure, more companies are encouraging investors to visit their websites – building the email alert lists through the sites, putting the web address on all materials, issuing advisory releases to direct people to the sites, and the like.

About 90% of the respondents file 8-Ks and issue news releases through paid wire services to get material news out to the market. (The IROs reported median annual cost of $25,000 for issuing press releases.) After those two channels come conference calls, email alerts, RSS feeds and social media.

A few companies are pushing the envelope. Google created ripples in the IR community by reporting Q1 earnings on its IR website in April – and not providing a detailed release through a newswire. A 3-sentence alert through a newswire did point market participants to the website posting:

Google Inc. (NASDAQ: GOOG) has released its first quarter 2010 financial results. Please visit Google’s investor relations website at http://investor.google.com to view the earnings release. Google intends to make future announcements regarding its financial performance exclusively through its investor relations website.

Google’s move stirred some controversy. Reuters clucked that this “unorthodox” approach “raises questions.” Dominic Jones of IR Web Report sprang to GOOG’s defense and went after Reuters. I’ve heard other IR people give varying opinions.

My feeling? Google can do whatever it wants, of course. I view company news more from a communication standpoint than a legal one. For most companies, the goal should be to reach as many investors and other stakeholders as possible with earnings or another announcement. I would add channels, not cut them off.

At this stage, having your press release feed automatically into Bloomberg screens, Yahoo! Finance and all those other channels (even Google search) seems desirable. Transparency includes making it easy to find your information. Requiring an investor to visit your website, adding clicks to the process, or pushing more people to read news filtered through reporters for Reuters or Bloomberg, seems limiting.

I’m all for robust websites. As I’ve said before (see “The website: your front door”), IROs should view a company site as the potential investor’s entry point to engage the business. We should evaluate the experience a person has approaching that front door – and benchmark how we do providing information, creating impressions and inviting interaction. Ease of use and transparency should characterize a website. But the site isn’t the only channel.

What’s your opinion on the place of websites in good disclosure? Comment below.

© 2010 Johnson Strategic Communications Inc.

Should your CEO do social media?

May 10, 2010

George Colony, tech guru and chief executive of Forrester Research, packs an interview on Mashable with common-sense advice on how a corporate CEO should relate to social media. (Mashable is a news and opinion site devoted to Web 2.0.) The Forrester interview is a good read for investor relations staff and counselors.

Three factors are working against CEOs embracing social media, Colony says:

  • Age – the typical CEO grew up back when people talked
  • Regulatory constraints – the risks remain fuzzy around Reg FD and new media networks like Twitter (ignore Mashable’s mistake in transcribing SEC as FCC in the text)
  • Time – or the lack of it.

The Forrester chief paints this picture of what keeps most CEOs from engaging:

If you go to a CEO and say — and this is sort of conventional wisdom around being social — “We want you to make between five and six 140-character statements a day” — that’s 30 a week. “Then we want you to make one large statement per week — about four or five paragraphs.” And most CEOs would say, “There’s absolutely no way I could do that.”

There are two problems here: one is time. Calculate the time behind this and it’s about five or six hours — that’s a lot of time for a CEO. The second is that model — which has become almost an accepted model if you want to build followership — that model is unsustainable if you want to sustain quality. In other words: There’s not enough to say. There’s not enough wisdom in the world for one person to be wise over all those statements to fall over a year. That’s 1,500 short statements a year and 50 large statements a year.

Colony favors what he calls “social lite” – a focus on quality rather than quantity. A CEO might aim to post significant messages 6 to 8 times a year on a blog, and perhaps comment every 2 weeks or once a month on a short-message platform like Twitter. So when the CEO does speak, it’s a more notable event.

The Forrester chief also says CEO posts should not be written by PR people – but by the CEO. That’s the point of social media, after all – to engage personally in the conversation. To fake it isn’t authentic, to use another social media buzzword. And a CEO doesn’t get the benefit of listening if he or she isn’t even in the room.

My feeling is that public company CEOs wading into social media should get a quick review of posts from other members of the team – say, the CFO, IRO or Legal. The idea is not to scrub the humanity out of the CEO’s words – no “writing by committee” allowed. But we should bring in a second set of eyes to check facts and grammar – just to protect to CEO and the company’s brand in the marketplace.

For most businesses, I favor something more like a company presence in a blog or on Twitter and Facebook – blending voices from marketing and corporate, either funneled through a single person whose job is “telling the story” or coming from several contributors writing on different aspects of the company and its products.

Colony estimates only about 10% of CEOs are ready to do social media now. In the next 10 years, that may grow to 50%. But he urges companies not to rush it:

I would say if you’re interested, explore — but do not force it. If you do not have the proclivity to communicate, to be a little bit honest, a little bit controversial, then I wouldn’t do it. I wouldn’t force it.

That view jibes with where most companies are now on social media – especially firms that are not in the tech business or that have small cap resources. It’s time to listen, explore, develop skills and resources – and “go social” as you are ready.

What’s your feeling on CEOs and social media? (Click comment line below.)

© 2010 Johnson Strategic Communications Inc.

Investors, golf, cancer & social media

May 7, 2010

Two communication folks from American Century Investments, a mutual fund firm with about $60 billion under management, gave a great talk today at the Social Media Club of Kansas City on an online campaign building the company’s brand.

As investor relations and corporate communication people at many companies are exploring social media – dipping our toes in the water – I thought I’d share some lessons from the American Century experience. They’re privately held, but dealing creatively with interactive new media in our highly regulated financial world.

Brent Bowen and Jamie Needham of American Century gave a case study on the American Century Championship celebrity golf tournament at Lake Tahoe – and what the company does to promote its brand through social media from the event.

Of course, the event starts with some advantages. This is golf, with a network TV audience that also can be online. The tourney draws celebrities ranging from Charles Barkley to Ray Romano. They’re playing because the event is a benefit for Lance Armstrong’s LIVESTRONG campaign against cancer. And golf is somehow woven into the DNA of many investors – American Century’s audience.

So it’s a natural. But the American Century team did a nice job with social media approaches that I think would fit for small or large companies – even firms that can’t bring Michael Jordan to their event. A video is available here (uncut, so fast-forward to ~12 minutes to skip Social Media Club housekeeping stuff).

My own interpretations from the American Century experience:

  • An event helps ignite the online conversation. To get people you’re not paying to start posting on Twitter or their Facebook pages, you’re best to tap into their interests with something that’s happening. Could be an earnings announcement, but don’t expect that one to go viral. Social media focus most easily on events that build corporate brand awareness or help launch products. IR is a smaller part of the picture – but should be present.
  • A feel-good cause gives momentum to a social media campaign because people get excited about doing good more than about a company making money. American Century wisely put all the emphasis on LIVESTRONG and helping cancer patients – all except, of course, that the event is called the American Century Championship. People who are online get excited about supporting cancer patients in the battle of their lives. Or about their favorite sport. Or an art show or concert. Or defeating hunger or disease.
  • Listening comes first. American Century started with “no social media presence – no Twitter account, no Facebook account” – Brent says. They began by searching out 20 to 25 key words in the online interactive space. What are people out there saying about us, our cause and our partners? They asked people in the industry what they want to hear – and the answer was, in addition to just investment products, to learn what makes the company tick. Investment people asked for that softer side, in other words.
  • Plan the content. As Brent says, “Content plan, content plan, content plan.” Sure, tweeting looks all spontaneous. When people post to Facebook it’s personal and folksy. YouTube videos capture those wacky moments. But the corporate message comes through because it is planned. Spontaneous stuff comes from being flexible in addition to following the plan.
  • Legal can get comfortable with social media. American Century puts on webinars in which its investment officers help the investing community understand what’s going on in the markets. The communications team decided to “live tweet” a webinar – which means giving a series of 140-character messages summarizing what the speakers say, as they say it. Anyone who follows @AmericanCentury gets the tweets in real time. The “story behind the story” is that a compliance officer sits next to the person doing the live tweeting – it’s real-time compliance review. Hey, IR could do that.

If you’d like more, watch this morning’s video or explore American Century’s golf tournament site. Congrats to this Kansas City company on a cool national event.

© 2010 Johnson Strategic Communications Inc.

Social media old & new

December 22, 2009

Christmas cards are the old social media – of the printing press era. But they say something to us about the new social media – our current interactive networks.

Personally, I love sending and receiving greetings this time of year. It’s a chance to touch old friends and colleagues with a personal wish of peace and well-being. I even like reading Christmas letters of faraway friends for news of their families and work lives.

A Wall Street Journal column on the history of Christmas cards this weekend made me reflect on how far we’ve come since Henry Cole printed up and mailed the first Christmas cards back in 1843. (No, Hallmark didn’t invent seasonal greetings.)

What’s this have to do with investor relations? Consider …

  • Relationships are built by communicating with people, repeatedly, often in different ways, over time. A Christmas card may be one touch. An email note or “retweet” on Twitter another. A phone call or one-on-one even better.
  • Social media are like Christmas cards. To play, you have to commit time and resources. You can’t say we’re going to do interactive media and then not put in the time – it’s like intending to send Christmas cards, but never getting to it.
  • Personal messages, even short ones, speak volumes. Just as the seasonal card is about letting someone know you’re thinking of them, any note or call tells an investor (or in-house colleague, for that matter) that you care.

So now’s the time to start on “social media” for 2010, whether your plan is to tweet your earnings, blog your strategy, engage in online conversations on your industry, upgrade your website, or just touch more people personally in the new year.

Oh, by the way, if you celebrate Christmas – Merry Christmas! If it’s a different holiday, best wishes in this beautiful season and all the best for the new year!

Word of the year: “unfriend”

November 17, 2009

The word of the year for 2009, according to the New Oxford American Dictionary:

unfriend.

This says something about our society and the social media we’re all embracing. Relationships of a certain sort are, well, un-doable. Someone can friend or follow you on Facebook, Twitter or LinkedIn, and either person can exit just as easily. Friending and unfriending can be entirely impersonal.

Now, I won’t say crack any cynical jokes about relationships with investors. My observation for the day is simply that we are all looking for real relationships – in our personal lives, business dealings … and our investor relations jobs.

Social media play a role in supporting all of these relational areas of life. But the simple act of friending or following or connecting isn’t much of a relationship. Talking with each other over time using whatever medium, listening, supporting – dare we say, investing time and effort in each other – makes a relationship.

Let’s be social in our investor relations outreach, but let’s build real relationships.

This space not for sale

October 9, 2009

NoSaleSignThe Federal Trade Commission this week jumped into a controversy that has been swirling in social media circles: “Pay for play” – the practice of companies or PR agencies paying bloggers, Twitterers and other online “influentials” to endorse or mention their products or services.

This FTC action focuses on people selling products – not pitching stocks. But the intervention in the online marketing world has important implications for online promoters of investments, as well. More on the investor relations side in a moment.

What the FTC did was announce new guidelines requiring disclosure if companies pay online chatterers, or give them free products, for endorsements. (FTC announcement here, old media take on it here.) So faking a word-of-mouth or “viral” phenomenon gets a bit harder. FTC explains:

The revised Guides also add new examples to illustrate the long standing principle that “material connections” (sometimes payments or free products) between advertisers and endorsers – connections that consumers would not expect – must be disclosed. These examples address what constitutes an endorsement when the message is conveyed by bloggers or other “word-of-mouth” marketers. The revised Guides specify that while decisions will be reached on a case-by-case basis, the post of a blogger who receives cash or in-kind payment to review a product is considered an endorsement. Thus, bloggers who make an endorsement must disclose the material connections they share with the seller of the product or service. … And a paid endorsement – like any other advertisement – is deceptive if it makes false or misleading claims.

For the record, this space is not for sale, regardless of FTC guidance. I have, in fact, received a couple of offers from IR service providers – but getting a paycheck isn’t the reason I’ve chosen to take part in the conversation through IR Café.

My ethic comes from years of working in the Old Journalism of daily newspapers. When I was a young reporter, one of the newsroom characters was a City Hall reporter known for, among other things, refusing to take a donut at the weekly City Council meeting because he never wanted to place his objectivity in doubt. A journalist who accepted freebies from someone he covered would be drawn and quartered, usually in a public flogging through a news story about his termination.

So I got the message: Journalism is about delivering information for the readers’ benefit; advertising is about being paid to deliver messages for advertisers’ benefit. Publishing ads is all well and good. But if you want credibility, the lines should not be blurred – as they increasingly are, both online and in traditional media.

I value credibility more than a buck, which is why I headline a post “This space not for sale.” If our firm tries to sell you something, you’ll know it.

Now, I have mixed feelings about the FTC sticking its nose into what has been a wide-open space on the Internet. Does freedom of speech extend to someone tweeting “Wow U have to try this new digicam from CoolVideo.com, best ever and an awesome Christmas gift, too!!!!!”  I don’t know, that’s marketing … or maybe constitutional law … a question above my pay grade, as the President says.

When it comes to investor relations, I have a clear opinion: Pay for play is not a good idea. Investors are smart enough to see through a paid profile in a publication or website aimed at investors, and it can hurt rather than help the company’s credibility. And people shouldn’t be touting stocks online (or touting the short side) for pay, period. Companies and IR or PR firms should steer completely clear of that practice – regardless of regulation. It’s a matter of integrity and credibility.

Securities laws outlaw market manipulation and misleading information, of course. I’m no expert on the Securities and Exchange Commission, but as interactive media play a growing role in capital markets, it wouldn’t be surprising to see the SEC take direct action to require disclosure of payments to bloggers or other online chatterers – just as analyst reports must disclose the i-banks’ interests in companies covered. It might even help clean up the markets.

What’s your opinion on the integrity – and freedom – of online discussions?

Not feeling ‘social’

October 5, 2009

Forty-nine percent of companies do not have a specific approach or policy on employees’ use of social media on behalf of the companies, according to a survey reported in the October 2009 PR Week (link here, but requires subscription).

Jim Tsokanos, president of North America for MS&L, a PR firm that sponsored the survey with PR Week, comments:

When we live in the world of the empowered consumer and everyone has a point of view, and they share it at the speed of light, for companies to not have policies in place to guide how social media can be utilized by their employees, I thought was very interesting.

You can tell he’s in PR: Dangerous might be a better word for half the companies lacking policies on social media use. The risk is especially acute for public companies, who could face serious disclosure issues or ethical breaches in a tweet.

As I’ve suggested before in IR Café, public companies need to develop policies on who can use social media to discuss the business and guidelines for how. (Links to examples of social media policies at this post.)

Investor relations professionals ought to offer input on social media, at least to address the defensive compliance issue – and, getting radical here, also to include the financial community proactively among audiences served via social media.

Don’t be ACORNed

September 28, 2009

Regardless of your politics, it’s clear that what happened to the activist group ACORN this month is an extraordinary case study in Web 2.0 and the rapid loss of reputation. It’s a new media nightmare.

Before answering “What’s this got to do with IR?” here’s a recap of the action:

acornACORN is the Association of Community Organizations for Reform Now. An advocate for the poor, labor and liberal causes, ACORN organizes voter registration drives, demonstrations and efforts to influence government or pressure businesses. While controversial and oft-accused of improprieties, ACORN has won victories against big companies and been an ally of some top Democratic leaders.

Along came two politically motivated social media types, James O’Keefe and Hannah Giles. Like other 20-somethings, O’Keefe has been producing videos for the Web – in his case, needling liberals. Giles, a 20-year-old college sophomore, got in touch with O’Keefe with an idea to go after ACORN with a made-up event.

The two concocted a scenario to test the community organizers’ integrity. O’Keefe would play the role of a pimp and Giles a prostitute. The pair gathered a few props, went on the road with a hidden camera, and set out to entrap ACORN.

Visiting ACORN offices in DC, New York, Baltimore, San Diego and San Bernadino, O’Keefe and Giles told ACORN counselors they needed advice on getting a house for the prostitution biz, hiding income from the IRS, avoiding police detection, and smuggling underage girls into the country to use as prostitutes.

The poseurs got their shocker. Some of the ACORN officials went along, seemingly ignoring the illegality and morally outrageous nature of acts they were discussing. The videos show ACORN people casually giving advice for how best to carry out and conceal the purported illegal enterprise. “Pimp” and “prostitute” seemed to be treated like any other client.

BigGovernment.com, a new conservative website, linked up with O’Keefe and Giles and used their sensationalized attack videos to create momentum for its September launch on the Internet. It’s been a success: The ACORN videos went viral, with links from a host of blogs and tweets; they were huge on YouTube; the slam on ACORN struck a chord with conservative talk hosts; and the controversy crossed over into mainstream media. Within days, Congress members were denouncing ACORN and voting to defund it. Everyone’s investigating.

ACORN has been tripping over itself with denials and counter-attacks. It denounced “indefensible” actions of its people and fired some. Accused the video makers of distortions and filed a lawsuit. Invoked the respected names of its silk-stocking Advisory Council. Posted its own video. Launched an “investigation” of itself. ACORN has tried all the usual reputation-defense tactics. But the damage is done.

This isn’t a small-time hit. BigGovernment is the brainchild of Andrew Breitbart, a conservative Internet entrepreneur who has worked with Drudge Report, a top right-leaning site, and a similar aggregator, Breitbart.com. The sophisticated distribution and marketing of the “news” is worthy of film propagandist Michael Moore or liberal political activists MoveOn.org. These people play hardball.

Well, enough politics. What does the ACORN story have to do with corporations and IR? Investor relations professionals need to envision, for a moment, the potential for a new media nightmare for their corporate reputations.

Build your own scenario. Imagine a couple of 20-somethings bent on doing damage to your company, products or industry. You can’t predict what store, office or plant they may visit. Starting with sophisticated new media skills, they add well-funded distribution – and show no civility or restraint in their attack.

Will the “gotcha” go viral? How much will it damage the company’s reputation?

The anti-business analogy to ACORN’s current organizational torment argues powerfully that companies need to prepare for potential crises created through interactive media channels. Skirmishes already have taken place – but may intensify.

Companies ought to minimize risk by being sure our people are all trained in ethical conduct. If we consistently do what’s right, it’s much less embarrassing. Culture can prevent problems – or not.

IR and other functions must develop robust social media skills, so we’re prepared before a crisis strikes. And we should invest in early warning systems – assuring timely internal communication, as well as monitoring the social and regular Web.

Our crisis communication plans – including IR components – must be up to the challenges of the 21st Century.

Don’t be ACORNed.

© Copyright 2009 Johnson Strategic Communications Inc.

Social media: Be a leader

September 18, 2009

Thinking a little more about investor relations engagement in social media (or hesitancy to engage), I believe IR people should step forward and offer some leadership in strategy and policies for corporate and employee involvement in the interactive Web. This is not to say take over, which IROs don’t have time to do and other departments would resist. But offer input, show thought leadership.

This issue came up today among IROs in a webinar on social media and IR organized by Bulldog Reporter’s IR Alert. I spoke on the panel but thought I would pull some thoughts – and resources – together to offer readers of IR Cafe.

Two compelling reasons for IR to lead internally and help shape the strategy:

The message. I think of IR as one of the keepers of the corporate brand. Who are we, what’s our story, what do we mean as a company, how do we create value in the world? The CEO, of course, is communicator-in-chief. But the IRO should be nearby, helping to clarify and deliver the message.

Yes, I know – the products are where the money comes from, so brand managers and marketing communications people often drive the agenda for media of all sorts, which now include Facebook, Twitter and the like. Most social media efforts spring from marketing, customers service or PR.But consider the audiences.

But communication strategy has to flow from understanding our audiences. We have customers, who may be learning about our products – or talking about them to friends – on networking platforms. We have employees, who may be talking about work and the company on social media sites. And we have investors – the IR audience – who own the company, after all, and increasingly are using social media to learn about it, in addition to the company website and traditional sources.

Go to search.twitter.com, a small but easy window into social media, and look for your company or big products. When I do this, I find a significant amount of chatter is on financial matters – investors trading links and opinions. We need to be sure the corporate story, the value-creation story, is reaching these audiences.

The risks. One role of IR within a company is to play gatekeeper – to be sure no one blabs the material information before the company properly discloses it to broad audiences. The IRO is, among other things, a Regulation FD gatekeeper.

Do we need to say what the risks are in social media? It’s a wild and woolly space. Consider the confidential information an employee might let slip, unthinking: We’re all excited about this new product that starts shipping November 1 … Everyone’s afraid of losing their job, because sales have just been tanking this summer … My division is being combined with this other one … The CEO had a heart attack.

I’m no lawyer, but what I’ve heard from several attorneys – including Ben Orlanski of Manatt, Phelps & Phillips on the webinar today – is that the same securities laws and SEC rules (reg FD!) apply to social media as everywhere else. So IROs should be involved, both in developing policies and in day-to-day activity, to guard against selective disclosure by the company – in Web 2.0 as well as other forums.

The other social media risk IROs talk about is the crisis. What happens when rogue employees post a YouTube video doing gross things with your pizza? Or angry soccer moms start tweeting and Facebooking about your TV commercial? Social media platforms spread information – true or false – rapidly and uncontrollably. That pizza video reached 1 million-plus viewers in three days, and investors were in the audience - the stock price dropped 13% (it has recovered). Crisis management is a topic unto itself, but the risk is reason to be prepared.

How to lead. As with so many areas of corporate policy and strategy, the influence of an IRO or outside agency is mostly informal – getting up to speed, reaching out internally to build support, be an active participant in a team. In the case of social media, that means working with Legal, Finance, Marketing, PR, Customer Service.

To me, decisions of where and how to engage in social media – blogs, Twitter, Facebook, there are hundreds of channels and tactics – are questions of strategy that each company must answer for itself. And no two approaches will be identical. But the necessity of thinking through the policy issues applies to every company.

Most public companies have disclosure policies, a giant “business conduct policy” and/or an array of policies covering various areas of employee conduct. Social media are relatively new, but already huge. So companies really need to update their policies to cover involvement of the company and employees in Web 2.0.

I’ve scanned some social media policies of big companies. The ones you can readily find on the Web are from tech companies, who have embraced the culture of sharing their information (even internal policies) online. Take a look at these:

I like Sun’s best among these, because of its plain English and subheads that guide the employee through it. Some business conduct policies are too lawyerly for most employees to get the message (or may even spawn little rebellions).

Charlene Li, co-author of Groundswell, has been preaching the “We need a policy” message for a long time. In a post from way back in 2004, she offers a simple example of a blogging policy, with links to more resources. So if you don’t have a policy that includes up-to-date thinking on social media, you need to catch up.

Communicating with the capital market has always been about using different channels to reach various segments of the investor audience, and IR 2.0 is here.

(Some previous posts and resources on this blog: IR 2.0 – A Menu linking to resources by topic, IR Website Checklist of what should be there, Tiptoeing into 2.0 on trends in corporate engagement, Twitter for IR? thoughts, Social media, reputation & IR, and Social media strategies: Talk, listen … or? Or go to the right side of this page, find “Browse by topic” and click IR 2.0 – Web & social media.)

Please comment with your ideas or links to social media & IR policies or resources.

Good news is, we’re all learning together. Have some fun along the way!

© Copyright 2009 Johnson Strategic Communications Inc.


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