Disclosure policy

Material information is any information relating to the business and affairs of Crew that could be reasonably expected to result in a significant change in the market price or value of the Company’s securities or in investment decisions.

It is the management team’s responsibility to determine what information is material in the context of the Company’s affairs. The team is in the best position to apply the definition of material information to Crew’s own unique circumstances.

In complying with the requirement to disclose all material information under applicable laws and stock exchange rules, Crew adheres to the following basic disclosure principles:

• Material information will be publicly disclosed immediately via news releases;
• In certain circumstances, the management team may determine that disclosure of certain information would be unduly detrimental to the company (for example, if release of the information would prejudice negotiations in a corporate transaction), and may keep the information confidential until the team determines it is appropriate to disclose it publicly. In such circumstances, the management team will cause a confidential material change report to be filed with the applicable securities regulators and will (at least every 10 days) review its decision to keep the information confidential;
• Disclosure must include any information that, if it were omitted, would make the rest of the disclosure misleading;
Unfavorable material information must be disclosed as promptly and completely as favorable information is;
• There can be no selective disclosure. Previously undisclosed material information must not be disclosed to selected individuals. If previously undisclosed material information has been inadvertently disclosed to any person who is not bound by an express confidentiality obligation, such information must be broadly disclosed immediately via news release;
• Disclosure made to analysts cannot be protected by a confidentiality agreement;
• Disclosure on Crew’s website alone does not constitute adequate disclosure of material information;
• Disclosure must be corrected immediately if the Company learns that earlier disclosure contained a material error at the time it was given.