Shareholder Investigation Announcement International News Distribution Execution Manual

I. Applicable Scenarios

This manual applies to the following scenarios:

• A law firm announces that it is conducting an investigation on behalf of shareholders against a listed company;
• A listed company receives regulatory inquiries or faces potential litigation and needs to disclose its current legal status externally;
• A company or institution needs to convey accurate information to stakeholders to prevent the spread of rumors.

Typical scenario example: In March 2026, a law firm published an announcement through an international news platform, declaring that it had initiated an investigation into a listed company, and disclosing that the company's stock price had fallen by more than 50% over the past year. The announcement provided investors with a clear channel of information, but also triggered a large number of media inquiries and investor consultations. At this point, the team needs a reusable publishing process to ensure consistent responses and compliant information.

Common issues:

• Unclear information boundaries, creating legal risks;
• Direct translation of complex legal information, resulting in ambiguity;
• Lack of follow-up communication, leading to the growth of rumors.

II. Goal Setting

Communication goals:

• Disclose necessary information in a lawful and compliant manner;
• Reduce investor uncertainty and consultation pressure;
• Leave an official record for possible future developments.

Audience goals:

• Existing shareholders and potential investors;
• Financial media and analysts;
• Regulators and stakeholders.

Information goals:

• Subject, time, scope, and current status of the event;
• Key impact on shareholders (e.g., stock price change range);
• Official channels for obtaining further information.

III. Preparation Phase

Information Preparation

• Establish a fact list: date of the event, entities involved, jurisdiction court or regulatory body, current procedural stage;
• Confirm data caliber: if citing stock price changes, indicate the starting time and range, for example, "from above $14.50 in April 2025 to below $7.25 as of the announcement date, a cumulative decline of more than 50%";
• Develop an FAQ: covering the most likely questions from the audience, including "What does the investigation mean," "Do shareholders need to proactively contact," and "What are the possible subsequent outcomes."

Market Preparation

• Determine target markets: based on the company's listing location, shareholder distribution, and media influence (e.g., the United States, the United Kingdom, Asia);
• Understand local reporting practices for legal investigation announcements; for example, U.S. markets more commonly cite law firm investigation announcements, while certain markets may require clearer regulatory phrasing;
• Confirm whether multilingual versions are needed and who will review each language version.

Resource Preparation

• Designate internal leads: legal (fact review), IR or communications (unified messaging), customer service (investor responses);
• Prepare content assets: press release templates, approved statements, media lists, stock price charts, etc.;
• Schedule: reserve at least 7 days to avoid last-minute publishing.

IV. Execution Phase### Phase 1: Fact-Checking and Legal Review (T-7 to T-5)

• Objective: Determine the boundaries of information that can be disclosed externally.
• Tasks: The legal team reviews all facts proposed for disclosure; confirm with decision-makers whether prior notification to the exchange or regulatory authorities is required; remove sensitive information from the press release.
• Output: A legally approved "core information page" of no more than 500 words, containing the 3 most essential items of information.
• Check: Whether each piece of information is supported by documents, records, or official statements; whether it may cause defamation or mislead.

Phase 2: Press Release Drafting and Localization (T-5 to T-3)

• Objective: Complete the content versions required for the target market.
• Tasks: Draft the master version based on the core information page; adjust wording according to the legal and customary expressions of different markets, for example, referring to an "investigation" as "investigation" or "inquiry"; add contact information available to local investors.
• Output: English version + target market language version (if needed); FAQ backup document; media distribution list.
• Check: The information in all language versions is fully consistent; professional terms have been confirmed by legal; contact information is correct.

Phase 3: Publication and Monitoring (T-3 to T+7)

• Objective: Deliver the information to media and investors at the scheduled time and conduct follow-up.
• Tasks: Select news distribution channels and set the publication time (usually on a local weekday morning); simultaneously send the press release to directly related media; monitor media citations and investor inquiries after the initial release.
• Output: Successfully published URL, list of media pickups, follow-up supplementary statement (if needed).
• Check: Whether mainstream media have picked it up within two hours after publication; whether the core data cited by media is accurate; whether the inquiry channels are accessible.

V. Timeline

• T-7 days: Hold an internal kickoff meeting and determine the scope of legal review.
• T-5 days: Complete the core information page, with feedback from all participants.
• T-3 days: Complete multilingual versions and FAQ, and confirm the publishing platform and time.
• T-1 day: Conduct an internal walkthrough, test the publishing system, and confirm the media list.
• T day: Publish the press release as planned and initiate media follow-up.
• T+1 day: Compile the first round of media reports and respond to repeated inquiries.
• T+7 days: Produce a communication effectiveness report, update the FAQ, or issue a supplementary statement.

VI. Checklist

□ The legal and disclosure boundaries for this announcement have been determined □ All financial data (such as stock price range, decline) have been verified and sources noted □ Written legal approval of the core information page has been obtained □ Target market language version has been prepared (if needed) □ The publishing platform has been confirmed and system testing completed □ A single point of contact for media and investor inquiries has been designated □ Monitoring keywords have been set up (e.g., "investigation," "shareholders," "stock price") □ Follow-up update templates have been prepared (e.g., "investigation progress" or "no new information")

VII. Risks and ConsiderationsRisk 1: Publishing a single announcement and neglecting follow-up maintenance.

Why it happens: The team treats the announcement as a one-time task; Mitigation: Include T+1 and T+7 in the timeline and prepare a "no new information" template in advance.

Risk 2: Ignoring local regulatory and language environments. Why it happens: Assuming English alone covers the global audience; Mitigation: For key markets, have local legal counsel review the wording to eliminate language and regulatory ambiguity.

Risk 3: Data errors causing a collapse of trust. Why it happens: Time pressure or financial data not being re-verified; Mitigation: All data must be verified by designated personnel; ideally, the finance department provides written confirmation.

Risk 4: Information framework built from the institution's perspective rather than the investor's. Why it happens: The press release only describes "what we did"; Mitigation: Based on the FAQ, start by writing "what this means for shareholders."

Risk 5: Lack of internal coordination leading to inconsistent messaging. Why it happens: IR, customer service, and executives each respond to inquiries separately; Mitigation: Hold a briefing before publication to align messaging and provide talking-point cards.

Risk 6: Vague objectives that only chase exposure. Why it happens: The only requirement is "get in the news"; Mitigation: Set measurable goals, such as "covered by 5 mainstream financial media outlets with accurate citation of core data."

VIII. Effect Evaluation

Communication metrics:

• Number of media pickups within 48 hours after the press release;
• Proportion of key data (stock price decline, investigation scope) correctly cited;
• Traffic to the official website or official statement page.

Awareness metrics:

• Whether the FAQ coverage rate in investor inquiries exceeds 60%;
• Whether media questions remain concentrated within the approved information scope;
• Whether new questions requiring additional clarification arise at the press conference.

Long-term metrics:

• Visibility of the announcement in search engines, becoming a cited source for subsequent related coverage;
• Whether subsequent investigation updates are more easily picked up by media;
• Whether official digital assets (press releases, FAQ, statement pages) continue to receive traffic.

IX. Retrospective Optimization

After the project ends, answer the following questions:

• Which steps took longer than expected (e.g., legal review, translation)? Can they be pre-reviewed in advance next time?
• Which media channels responded fastest? Which markets performed better? Should the distribution list be adjusted?
• Were there any media misreadings or investor misunderstandings? Is it necessary to add more background explanations to the template?
• Do the costs and benefits of multiple language versions match? Should fewer languages be used or more localized channels added?
• If a similar investigation announcement occurs next time, how many materials and templates can be reused?

X. Writing Focus for Different Playbook Types (this manual corresponds to global press release distribution)Information preparation: news value derives from the impact of the event; the time, subject, and scope of impact must be clarified.

News value assessment: matters involving shareholder rights, stock price fluctuations, and legal procedures are all reportable dimensions; however, statements must be restrained. Target market selection: prioritize coverage of the company's listing location and shareholder locations, then expand to international financial media. Content localization: not only translate the language, but also adjust legal terminology, data presentation, and contact information conventions. Publishing rhythm: it is recommended to publish on weekday mornings, leaving sufficient response windows, and avoid Fridays or holidays. Follow-up observation: after T+7, keywords should still be searched regularly to promptly respond to new questions.