Speeches and Public Writing Policy

Purpose

To make sure any public speech, published article, or similar public communication that identifies the employee with the Company, or discusses Company business, reflects the Company accurately and doesn't create unintended legal, competitive, or reputational exposure.

Policy

An employee may not represent the Company in a public speech or in an article or post for publication unless it has been cleared through Communications/PR (or a designated executive) in advance. This applies whenever the speaker or writer is:

• identified as a Company employee, and
• speaking or writing on a subject involving the Company.

It does not apply to purely personal opinions expressed in a personal capacity, where the employee makes clear they are not speaking for the Company and the subject matter does not involve confidential or proprietary Company information. (See also the Company's Blogging / Social Media policy for guidance on that distinction.)

Does not restrict protected concerted activity. Nothing in this policy requires approval before, or otherwise restricts, an employee's statements — to the media, on social media, or otherwise in public — about wages, hours, or other terms and conditions of employment made in connection with, or in support of, group action with one or more coworkers (for example, discussing pay or working conditions, or raising a group workplace concern publicly). This protection, under Section 7 of the National Labor Relations Act, applies regardless of whether the workplace is unionized. This policy's approval requirement is intended to reach the Company's public messaging (speeches, bylined articles, and similar communications made or perceived as being made on the Company's behalf) — it is not intended to, and must not be applied to, require advance approval for an employee's protected discussion of their own or coworkers' pay or working conditions. If there is any doubt whether a planned communication falls into the protected category, consult Legal/Employee Relations before requiring approval or taking any adverse action.

Guidelines

Before delivering a speech or submitting an article for publication:

1. Submit the manuscript or outline to your manager and function head, allowing adequate time for review before it needs to be used.
2. Once management approves, forward it to Communications/PR for final clearance. Do not deliver the speech or publish the article until that approval is received.
3. Include with the submission:

• The occasion, organization, date, and location (or the publication name and date).
• Who invited the speech or article, and their title.
• The name and title of the Company employee delivering the speech or authoring the piece.
• The name and title of whoever approved the speech or article being given/written, and whoever gave final approval.

Responsibilities

Role	Responsibilities
Employee	Submit the manuscript/outline for review before committing to speak or publish.
Manager / function head	Review and approve.
Communications / Public Relations	Grant final approval.

References

• Media Inquiries policy
• Confidential Information / Non-Disclosure policy
• Blogging / Social Media policy