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AIM companies must ensure robust social media policies

27 Jan 2017

AIM companies are being reminded to ensure an adequate social media policy is in force and regularly reviewed, here’s what you need to know

Do you have a social media policy? You should

As you’ll see from this recent AIM disciplinary notice, an un-named AIM listed company was recently fined £75,000 for a breach of AIM Rule 31. You can read the AIM Rules for Companies, but rule 31 follows:

AIM company and directors’ responsibility for compliance 31. An AIM company must:

  • have in place sufficient procedures, resources and controls to enable it to comply with these rules;
  • seek advice from its nominated adviser regarding its compliance with these rules whenever appropriate and take that advice into account;
  • provide its nominated adviser with any information it reasonably requests or requires in order for that nominated adviser to carry out its responsibilities under
    these rules and the AIM Rules for Nominated Advisers, including any proposed changes to the board of directors and provision of draft notifications in advance;
  • ensure that each of its directors accepts full responsibility, collectively and individually, for its compliance with these rules; and
  • ensure that each director discloses to the AIM company without delay all information which the AIM company needs in order to comply with rule 17 insofar as that information is known to the director or could with reasonable diligence be ascertained by the director.

The disciplinary notice doesn’t mention social media specifically, but we understand the company in question was fined predominately as a result of information that was disseminated over Twitter that had not been approved by the AIM companies’ NOMAD, or previously sent over an approved Regulatory Information Source (RIS) such as RNS.

The notice goes on to confirm that the NOMAD should be involved at every step to ensure compliance with fair disclosure rules, and Twitter is seen as a communication medium like any other. This goes for the personal accounts of company Directors, as well as the company account itself. If you’re not sure, check with your NOMAD for guidance before sending that Tweet.

In addition to the disciplinary notice and substantial fine, which highlights that AIM is taking such breaches very seriously, the December edition of Inside AIM goes on to cover social media usage in greater detail. Disclosing information on Twitter alone isn’t enough to meet obligations, and companies should also consider their obligations under the Market Abuse Regulation (MAR) separately too.

How to make social media work for you

As we’ve already covered, it’s important to have a policy. There’s no single solution that’s right for everyone. The size of your company and your intended audiences will likely dictate your companies’ social media policy. In essence, the policy should cover what news you will share, how it will be shared, where and with what frequency.

Monitor sentiment across platforms and forums. Understanding what is already being said about you even if you’re not actively engaged and posting content directly can prove a useful strategy. Understanding casual market sentiment can help drive other aspects of the business and provide additional insights that shouldn’t be ignored. We can help here if you’re interested. You can be sure your stakeholders are already using these channels even if you aren’t, so we recommend you watch the conversations even if you don’t intend on taking part.

Be ready to control the message if needed. We can’t predict what might happen in the future, but social media tends to be used heavily in times of crisis. This could even be something as simple as lower than expected results, and this type of news will often act as a catalyst for discussion and speculation among audiences. Agreeing in advance how you will deal with these situations if they arise will allow you to respond quickly and directly with your voice. Who will make the communication? What will you comment on and what will you ignore? Which platforms are you most concerned about? These are all questions you should have answers to now.

Each social media channel requires different considerations. For example, Twitter might be a great place to build your following and awareness and you could achieve this by reposting regulatory content (after it has hit the wires already of course!). Conversely LinkedIn is a great place to share more general company announcements and advertise for job openings. YouTube might also offer another way for you to share company video produced elsewhere, allowing you to curate a timeline of video posts that is easily accessible by those looking for greater insight on your company and its operations. Branding, commercial and consumer content is perhaps best left to the likes of Flickr, Instagram and of course Facebook.

Make your social media channels your own. It’s a bit obvious, but we’ve seen evidence of companies who haven’t made the most of the personalisation available on each platform to truly brand and customise their channels. Social media is rife with copycats and fake or unofficial accounts and one of the first things users will be looking for before they follow is confirmation that it’s the real you. Going the extra mile with cohesive and consistent branding across each channel will help you to be recognised while reinforcing your corporate identity. You could also extend your social media policy to include key staff and their business (or even personal) accounts for a united view.

Promote social media within your corporate website. Facebook and Twitter make it very easy to integrate and embed your recent activity within web pages, usually at the click of a few buttons. As a demonstration you’ll see we’ve embedded our Twitter feed at the top of the right hand column of this blog post, and also on our Home page. Embedding like this helps to promote the channels and increase your followers, and it can also provide a “social hub” allowing users to review recent posts across multiple channels from a single page. You can also add more simple buttons leading off to your channels, alongside social share icons on your news pages to encourage others to share and spread your message.

Remember, it’s the world-wide web. Social Media is a great tool for disseminating content far and wide and should definitely form part of a global or multi-market communications strategy. You will of course need to be mindful of regulatory disclosure rules in other regions (for example, we often have to add a disclaimer to regulatory news announcements excluding various territories from reading it), but in a general sense you can use social media as another tool to reach audiences in non-domestic markets.

Is it working? Review and measure engagement. Pumping content out continuously is great, but how do you know if it’s working? Being able to measure engagement levels will help you identify what works and what doesn’t, and the results of your social media analytics can help you refine and improve your social media policy.

If you’re looking for more practical advice on the subject perhaps take a look at this CMS Law Now blog post for further insight.