This policy provides the Company’s expectations of its workers in communicating and establishes the principles and ‘rules’ that guide the company’s decisions when it comes to communication.
1. Introduction
Transcorp Hotels Plc (“the Company”) and its employees interact internally with each other and externally with external stakeholders in various ways. Such interaction could be in the form of emails, press releases, newsletters, advertorials, tweets, other social media communication, etc. Employees may also be invited to speak or participate in various public functions in an official capacity. In certain instances, third party vendors or contractors may also be required to communicate on behalf of the Company.
In view of the foregoing, it is imperative that the principles that will govern any form of corporate communication in the Company are clearly defined.
2. Purpose
The objectives of this Policy are as follows:
2.1 To encourage effective internal communication within the Company’s employees.
2.2 To encourage effective communication with external stakeholders providing them with open, accurate, clear and transparent information about our mission, strategy, objectives and achievements.
2.3 To provide clear directions to all employees on how to communicate Company’s publicly available information.
2.4 To help employees understand the Company’s communication style regarding non-public information as well as the people authorised to handle such information.
2.5 To clarify the restrictions on communication with the media.
2.6 To streamline the process of accepting public speaking appointments.
2.7 To set out the principles governing the use of the social media by employees.
2.8 To enhance the corporate reputation of Transcorp Hotels Plc through an accurate and appropriate representation of the image of the Company.
3. Scope
3.1 This Policy applies to all employees of the Company as it relates to any form of marketing and corporate communications across all relevant channels.
3.2 All vendors and contractors who are creating or contributing to blogs, social networking sites, discussion forums, or any other kind of social media on behalf of Transcorp Hotels Plc.
3.3 The policy applies, without exception, to all points of contact with consumers in all media, including Broadcast, Print, Outdoor advertising and billboards, Digital and other new media, Point-of-sale materials and merchandising, Labelling, Product names, Packaging, Consumer promotions, Events, Sampling, Sponsorship, among others. The Marketing and Corporate Communication Policy should be an integral part of any contract and/or included in the briefing for agencies developing marketing materials on behalf of Transcorp Hotels Plc.
3.4 This Corporate Communications Policy shall be applicable in conjunction with the Brand Guidelines, the Crisis Management Policy, and the Human Resources Policy Manual in place from time to time.
4. Responsibilities
The Head, Marketing & Corporate Communications (Head, MCC) shall have primary responsibility of implementing this Policy. The Head, MCC shall also be responsible for the day to day implementation and sensitisation of employees on the provisions of this Policy.
5. Definition of Terms
5.1 Restricted or Confidential information: information which is made available by the Managing Director/CEO or on the Managing Director/CEO’s directive to only select employees who by virtue of their position and authority need to know such information and disclosure of which can result in severe financial and reputational damage to the Company.
5.2 Internal communication: the transmission of information between Company’s employees. It takes place across all levels and departmental units within Transcorp Hotels Plc.
5.3 Publicly available information: information that is already legitimately available in the public domain (for example, information that is available to all Company’s employees, available on the Company’s website or contained in the Company’s external publications and reports).
5.4 Non-public information: all information that has not been made publicly available through media channels but has been disclosed internally to all Company’s employees.
5.5 Media: include print media, broadcast media, internet/wire news services, analyst reports and analysis, etc.
5.6 Stakeholders: people, groups, or organisations that have direct or indirect stake in Transcorp Hotels Plc because they can affect or be affected by Company’s actions, objectives, and policies.
5.7 External stakeholders: include the media, rating agencies, regulators, vendors, government and governmental agencies, business partners, financial institutions, etc.
6. Email Communication
6.1 Email communication may be internally to Company’s employees or externally to external stakeholders. Care must be taken when sending official emails as they could have severe legal consequences for the sender and the Company.
6.2 All communication internally and externally should be written in British English.
6.3 All employees shall read their e-mail messages regularly and promptly respond to emails received.
6.4 All emails sent by Company’s employees shall be sent with the official e-mail signature, format, font size, style and colour.
6.5 Where emails are sent from mobile phones, employees shall ensure that their mobile phone email settings have been correctly configured to the official email signature format before sending official emails.
6.6 E-mails shall contain sufficient information to ensure that they are properly contextualised and that they are meaningful and accessible over time.
6.7 Emails shall always be properly constructed in professional and courteous language. Abbreviations, colloquial language, and slangs shall not be used in official email communication.
6.8 Unnecessary emails should be avoided. Employees should make use of verbal discussions when seeking minor clarification on any subject or when they require an immediate response to an issue.
6.9 Subject lines are very important, since they indicate to a recipient what the message is all about. If subject lines are not used appropriately, the recipients may not realise the importance of the message and choose to read it later or not at all. Employees shall allocate useful subject lines to e-mails.
6.10 If an employee receives a message with an inadequate or meaningless subject line and needs to reply to or forward it, the subject line should be changed to properly cover the subject of the e-mail before sending.
6.11 Employees shall not originate or distribute any offensive, junk, defamatory, obscene, pornographic, political, religious, offensive, or illegal e-mail received from any other user or external network.
6.12 Employees shall not send jokes, games, gossip news, or other nonprofessional messages using official emails.
6.12.1 Employees shall not send emails that:
6.12.1.1 Advertise any personal service or promote any private business endeavour.
6.12.1.2 Contain information that is confidential, critical, or commercially sensitive to employees that are not authorised to receive such confidential information or to external parties.
6.12.1.3 May damage the Company’s reputation or its relationship with its business partners, or which may embarrass business partners and affiliates of Transcorp Hotels Plc.
6.12.1.4 Makes representations or express opinions purporting to be those of the Company.
6.12.2 Email distribution lists (such as All Staff Newsfeed, EMC members, etc.) shall be used carefully and only upon proper consideration.
6.12.3 Employees should avoid the use of the ‘Reply All’ option when responding to email unless all other persons copied on the email require the information being sent.
6.12.4 Employees shall not forward internal communication memos/mails or internal mails generated from internal discussions on a subject to external parties.
6.12.5 Employees should avoid amending or editing emails they receive when forwarding same.
6.12.6 Employees should re-read all outgoing emails before clicking ‘send’.
7. External Communication
7.1 General
7.1.1 External stakeholders should be informed of major business events affecting the Company in a factual and timely manner.
7.1.2 Transcorp Hotels Plc communicates and markets its different businesses to a diverse set of stakeholders that operate in different legal, regulatory, and cultural environment.
7.1.3 Good and effective communication safeguards the Company’s reputation, results in supportive stakeholders, builds our brand and leads to sustainable value.
7.1.4 Our communication must be in line with all regulatory requirements in all areas of our business.
7.2 Communication of publicly available information
7.2.1 Transcorp Hotels Plc supports the participation of all employees in helping to build our brand. However, this shall be done through knowledgeable and accurate communication of the Company’s key messages whether in business or social settings.
7.2.2 Information shall be deemed to be publicly available if it has been officially communicated to all staff from the Executive Office by email or at staff meetings, unless otherwise stated.
7.2.3 When presentations are prepared for internal or external use, the appropriate presentation template shall be used.
7.2.4 All presentations prepared for external purposes shall be reviewed and approved by the Managing Director/CEO or by any senior management staff designated by the Managing Director/CEO.
7.3 Communication with the media
7.3.1 The media are both a key audience and a major influencer of other stakeholders of the Company and therefore play a big role in shaping the Company’s reputation. Accordingly, communication with the media shall be carefully managed and thoroughly coordinated.
7.3.2 Communication with the media, both in formal and informal environments and in any form of platform (including social media) is strictly within the purview of authorised spokespersons.
7.3.3 The following rules apply to all communication with the media:
7.3.3.1 All media contacts shall be managed through the Head, MCC.
7.3.3.2 All press releases and other forms of communication with the media shall be approved by the Managing Director/CEO before being issued or released.
7.3.3.3 All media queries shall immediately be referred to the Head, MCC and the Managing Director/CEO.
7.3.3.4 All approved media spokespersons shall undergo media and communications training.
7.3.3.5 All approved media spokespersons shall restrict their comments to their areas of expertise as approved by the Managing Director/CEO.
7.3.3.6 Unauthorised comments are strictly prohibited.
7.3.3.7 In instances where an unauthorised spokesperson is accosted by the media with questions concerning the affairs of the Company, the following standard response shall be used: “I am not authorised to speak with the media. However, I will refer you to our Head of Marketing & Corporate Communications.”
7.3.3.8 If you are authorised to speak to or with the media and you are not quite certain about the adequate response to give to the question(s) posed, politely end the discussion and direct the media representative to the Head, Marketing & Corporate Communications.
7.3.3.9 If you are an approved Media spokesperson, prepare the message thoroughly. Review with Management and consider the likely reaction when such messages are delivered directly to any/all of Company’s key audiences.
7.3.3.10 Consult the Managing Director/CEO to agree on all messages before talking to the Media.
7.3.3.11 Never give any information to the Media unless:
7.3.3.12 Interviews related to financial performance shall be granted by the Managing Director/CEO or the authorised designated representative.
7.3.3.13 Employees shall obtain pre-approval from the Managing Director/CEO or the Head, MCC prior to accepting requests to contribute articles to the media or any other type of report or publication. If approval has been granted, the content must be reviewed with a sign-off before publication.
7.3.3.14 Employees are permitted to speak to the media in their personal capacity as long as there is no reference to the Company.
7.3.3.15 In the event of rumours, speculations or insinuations about the Company, members of staff are advised not to make comments either in a personal or official capacity.
7.4 Communication with Regulators
7.4.1 In most instances, communication with regulators is done in compliance with regulatory obligations such as the filing of returns and submission of information. Such returns or submissions shall only be filed and signed by the required officers of the Company.
7.4.2 All other engagement with regulators should be approved by the Managing Director/CEO on advice from the Legal & Compliance unit.
7.5 Management of confidential information
The provisions of the Code of Conduct shall apply in matters relating to confidential information.
7.6 Communication of non-public information
7.6.1 Communication of non-public information shall always be treated with extreme care. This is because any leak of non-public information to the public may expose Company to reputational risk.
7.6.2 The following rules shall apply to communication of non-public information:
7.6.2.1 Only the Chairman or Managing Director/CEO is authorised to communicate non-public information to our stakeholders.
7.6.2.2 Where in doubt of what constitutes non-public information, please check with the Head, MCC.
7.6.2.3 Employees shall not provide non-public information to any source unless:
7.7 World Wide Web
7.7.1 The standards for the Company web presence are created and managed by MCC.
7.7.2 Other employees (outside the MCC team), agencies and other stakeholders are not authorised to place information of any kind regarding the Company or its operations or plans on any portion of the web.
7.7.3 Individual employees of the Company are prohibited from using, or approving the use of the Company’s logos, copyrighted or proprietary materials of the Company on the web without the Managing Directors/CEO’s approval.
7.7.4 All requests to register domain names on behalf of the Company anywhere in the world shall be coordinated by the MCC Department. This is to ensure consistency, total brand protection and functionality of our web presence.
7.7.5 The use of any of the Company’s logo on a third-party website requires prior consent in writing from the Managing Director/CEO.
7.8 Public speaking offers
7.8.1 Any staff that receives an offer to speak or participate in any official function shall follow the following procedure:
7.8.1.1 Prepare a request for approval, which shall include the name and location of the organisation that sent in the request, the nature of the speaking engagement or forum as well as the general and specific subject matter.
7.8.1.2 Check with their line manager to confirm that the event would not negatively affect the Company’s business activities.
7.8.1.3 Check with the Head, MCC to ensure that the speech or the event will not negatively affect Company’s brand.
7.8.1.4 Seek approval to speak or participate in the event from the Managing Director/CEO.
7.8.1.5 Where approval is not granted, the request shall be returned to the staff with the reasons for withholding approval clearly specified.
7.8.1.6 Whether approval is granted or not, the staff is required to write the requesting organisation to subsequently route such letters through the Executive Office.
7.8.1.7 Where a staff has fore-knowledge of the event, he/she shall request the organiser to send the invitation directly to the Executive Office.
7.8.1.8 In such an instance, the Managing Director/CEO shall then decide, through the Executive Office, whether the staff shall participate in the event or not.
7.8.2 Filing of Presentation Materials: where a staff obtains approval to participate in a public event, all presentation materials shall be submitted to the MCC Department for record purposes.
7.8.3 Honorarium: Honorarium received by staff involved in speaking and related assignments on behalf of Company shall be treated in line with the Human Resources Policy Manual.
7.9 Social media
7.9.1 Transcorp Hotels Plc is committed to ensuring that its employees participate privately in the social media the right way and use the social media to enhance Company’s brand. Employees are representatives of the Company and should be aware of how their personal actions impact the Company’s brand and credibility of all Company business units.
7.9.2 Social media channels include the following:
7.9.3 The Company empowers employees to use social media to publicly promote and champion programmes of the Company and its affiliates, as well as to facilitate collaboration and innovation.
7.9.4 The Company participates on social media through its official social media accounts. Employees are encouraged to connect with the Company on social media using their personal social media accounts.
7.9.5 Only authorised members of MCC are permitted to prepare and modify the contents of the Company’s official social media accounts.
7.9.6 Only authorised members of MCC are permitted to engage with news media or industry analysts. This is to ensure that the Company communicates with the media in a consistent, timely, and professional manner about matters related to the organisation.
7.9.7 In the event of rumours, speculations or insinuations or any news about the Company being published on any blog, forum or other social media or online news platform, employees shall not participate or comment on such matter, whether to clarify or defend the Company or otherwise. Any response to such matters shall be provided through the Company’s official social media accounts. Employees are however encouraged to notify the Head, MCC where they become aware of any such post, for immediate official action.
7.9.8 Employees shall not disparage the Company’s services, or services of the Company’s vendors or competitors. This includes both individuals and institutions. Examples of such conduct include offensive posts meant to intentionally harm someone’s reputation and posts that could contribute to a hostile work environment on the basis of age, race, religion, sex, ethnicity, nationality, disability or other protected class, status or characteristic.
7.9.9 If you see something online that alleges potentially unlawful or unethical conduct (for example illegal, and unsafe or unethical conduct by an employee, contractor, or vendor), please immediately escalate this to: mcc@transcorphotelsplc.com
7.9.10 The following guidelines shall apply to personal social media accounts:
7.9.10.1 A personal account should focus on the employee’s personal life.
7.9.10.2 Employees can post publicly available official information on their personal accounts.
7.9.10.3 When you are participating on social networking sites using your personal social media accounts, be transparent that your thoughts are your own if discussing official Company business. Use your real identity—no aliases— and disclose your affiliation with the Company. Employees who refuse to do this will face subsequent management action. If you believe your posting might lead to any confusion with viewers about whether you are speaking on behalf of the Company, you should clearly and specifically state as follows:
Disclaimer: “These tweets/posts are my own, not Transcorp Hotels.”
7.9.10.4 Employees shall not disclose the following types of information in their personal accounts:
7.9.10.5 If an employee represents himself/herself as an employee of Transcorp Hotels Plc on social networking sites like LinkedIn, the employee shall not provide professional references for any current or former Company employee, contactor, vendor, or contingent worker on the Company’s behalf. However, an employee may provide a personal reference or recommendation for current or former Company employees, contractors, vendors, and contingent workers provided a) the statements made and information provided in the reference are factually accurate; and b) you include the following disclaimer:
“This reference is being made by me in a personal capacity. It is not intended and should not be construed as a reference from Transcorp Hotels Plc.”
7.9.10.6 Employees shall avoid inappropriate content that could be linked to the Company, which may adversely affect the employee’s reputation or the Company’s brand and reputation.
7.9.10.7 Everyone should be guided by the principle; when in doubt, do not post.
7.9.10.8 In all, employees are advised to be guided by the following leading practices in their social media communications:
7.9.10.9 If an employee’s personal account contains any brand-related or copyright material belonging to the Company, the employee shall change or remove the material upon leaving the Company’s employment.
8. Non-Compliance
Non-compliance with this policy shall attract disciplinary actions in line with the provisions of the Disciplinary Process and Sanctions Grid Policy.
9. Waivers
The Managing Director/CEO shall approve all requests for any waiver to this Policy. All such waiver approvals shall be obtained in writing and kept as a record by the policy owner.
10. Delegation
Any delegation of authority conferred by this Policy shall be in accordance with the approved procedure for the delegation of authority as set out in the Delegation of Authority & Empowerment policy.
11. Review and Amendment
This Policy shall be reviewed every three (3) years by the policy owner, and may be amended, subject to approval, if deemed necessary. The Company however reserves the right to change any of the provisions of this policy as it deems fit or required from time to time and such change shall apply to all Staff of the Company from the date of change as it relates to the subject-matter.
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