Canadian Wheat Board

Prairie strong, worldwide

Information Policy

PART I: BACKGROUND & RATIONALE FOR POLICY

As a producer controlled marketing organization, the Canadian Wheat Board (CWB) has a responsibility to provide meaningful and relevant information to its farmer shareholders. Information is key to increasing producer knowledge and understanding of CWB operations and performance, and will ensure that the CWB is accountable and meets producers' needs.

The goals of the Information Policy are to:

  1. Enable farmers to make a meaningful assessment of CWB performance
  2. Provide meaningful and relevant information to farmers for use in their operations
  3. Ensure farmers' and the CWB's strategic and commercial interests are not placed at a competitive disadvantage by any information release
INFORMATION THAT MUST BE PROVIDED TO CWB FARMER SHAREHOLDERS

The CWB is a producer-controlled organization with ten of the 15 Board of Directors elected by farmers. These farmer-elected directors are the voice of Prairie farmers, ensuring that the CWB is working to advance and protect farmers' interests. The Board of Directors must be satisfied that the CWB is acting in farmers' best interests. They have the power to access confidential individual sales transaction information (and other operational information) to ensure that the CWB is acting in farmers' commercial interests.

Farmer shareholders need to be knowledgeable about single desk marketing and have access to meaningful and relevant information. Farmers have the right to information pertaining to CWB performance and information that will assist them in their operational decision-making. The CWB is already providing much of this information through PROs, market commentary, delivery-related information, etc. The CWB is also disclosing material changes and information as they affect farmer returns.

In order to advance and protect farmers' commercial interests, the CWB must remain competitive in the global marketplace. Clearly then, it is unreasonable to expect the CWB to disclose commercial or strategic information that would be used by competitors to gain advantage or market share. It is worth noting that no other commercial organization reveals any information pertaining to specific transactions, nor do they release any information that would identify individual customers or shareholders.

VALUE-RELATED INFORMATION

Farmers need to know the value that the CWB creates for farmers compared to what they would receive in the CWB's absence. While a shareholder of a publicly traded company tracks return on investment through share value and other financial information disclosed by the company, a farmer delivering to the CWB needs another mechanism of evaluation. CWB sales performance as well as other aspects of operational performance will be studied and benchmarked, and this information provided to farmer shareholders.

MATERIAL INFORMATION

The CWB currently advises farmers of material changes and information pertaining to CWB business and affairs. This type of material information could include any company changes or information pertaining to CWB business and affairs that will substantially affect farmers' expected final returns and which is not commercially and/or strategically sensitive. Examples of this information include, but are not limited to, the implementation of policies by competitors or by exporting or importing countries that could affect CWB market share, or significant changes to the management team.

COMMERCIAL AND STRATEGIC INFORMATION

Companies typically do not release commercially or strategically sensitive information. To do so would compromise their market share or commercial position in the marketplace. In the CWB's case, the disclosure of commercially and/or strategically sensitive information could seriously harm Prairie farmers' interests. If the CWB made sensitive information public, then customers, competitors, and service providers would have information that they would otherwise not be able to access. This would put the CWB at a competitive disadvantage.

PART II: THE INFORMATION POLICY

This Information Policy outlines the principles guiding the release of information upon public request. Note: the CWB currently discloses routine information through news releases, annual reports, PROs, the Web site, Grain Matters, and other publications.

The CWB is committed to providing information in a manner that complies with all legal requirements, and meets the criteria outlined within this Information Policy. Subject to the foregoing, information will be disclosed in an even-handed manner and without discrimination.

HOW TO MAKE AN INFORMATION REQUEST

Send information requests to the Information Officer, Office of the Corporate Secretary, the Canadian Wheat Board. Requests must be in writing, outlining the exact purpose for which the data or information is to be used, timeframe requested, and any other specifics of the request.

WHAT TO EXPECT AFTER MAKING A REQUEST

Replies to information requests will generally be made within 15 days. The response will either identify that the request has been approved, with the applicable fee and expected date of delivery, or that the request has been denied and the rationale for the denial. If the request is onerous in nature, the CWB will notify the requestor, by telephone, of the anticipated response time.

Furthermore, on onerous or unclear requests, the Information Officer will contact the requestor to define the request more precisely and/or narrow the request. In the event that the resubmitted request cannot be narrowed or more precisely defined, and the CWB is unable to fulfil the request without retaining additional resources, the CWB may refuse to fulfil the request.

FEES

Fees for requests will be based on how much administration will be required to evaluate the request and assemble and review the requested information.

Fees may not be charged if the request relates to the administration of a government farm program or initiative, such as crop insurance, safety net programs or distribution of information of interest to permit book holders. Fees will also not be charged for information released to grain companies to be used strictly for administrative purposes in their role as agents of the CWB.

The CWB will charge a fee for the production of the information pertaining to a non-routine request. This fee will cover all staff, computer and other information gathering costs related to the production of the data. Non-routine requests include sensitive information that has never been released, or requests that are broad or unclear.

INFORMATION TO BE DISCLOSED

The CWB's vision is to create value for Prairie farmers by being an innovative world leader in marketing grain. Consistent with this vision, the CWB will disclose the following types of information, subject to the considerations noted in Part 1 of the Policy:

Information on finalized policies, programs, and reports will be provided. Internal research, analysis or correspondence written for the preparation of these documents will not be released.

Information of a personal nature can only be released in accordance with the terms of the Privacy Act and will be accompanied by a letter stating that the information is to be kept strictly confidential and is to be used only for the purpose indicated.

REVIEWING EXTERNAL ANALYSTS' REPORTS

In cases where the CWB provides information or data to external analysts for use in their own research or modelling, the CWB retains the right to review the research or model for factual content. The management of this process will be co-ordinated by the Information Officer in collaboration with the Vice President, Corporate Policy and/or other officers whose operations are affected.

FORWARD-LOOKING DOCUMENTS

To the extent that forward looking information is provided in a CWB disclosure document, all statements are to be accompanied by appropriate contingency and cautionary language that has been approved by the Information Officer.

INFORMATION POSTED TO WEB SITE

All material of a sensitive nature posted to the CWB's Web site will be cleared with the Information Officer, in consultation with officers affected by the disclosure, prior to posting to the Web site. Best efforts will be made to ensure that Information posted to the Web site will be accurate and will not be misleading (i.e. out of date, incomplete, incorrect or omit a fact so as to make another statement misleading).

News releases will not be posted on the Web site or distributed by e-mail before they have been disseminated on a news wire service.

INFORMATION THAT WILL NOT BE DISCLOSED

Commercially sensitive information is any information, past or present, which could enable competitors, customers and/or service providers to gain a commercial advantage over the CWB or a third party. This includes, but is not limited to, proprietary information, details of marketing, and pricing.

Strategically sensitive information is any information, past or present, that could disclose or be detrimental to CWB strategies pertaining to, but not limited to, operations, negotiations, past pricing, planning processes or trade positions and/or which could enable competitors, customers and/or service providers to gain a commercial advantage over the CWB or a third party.

INFORMATION OFFICER

The Corporate Secretary (or any other officer who may be designated by the President & CEO) will be the officer responsible for the implementation of this Information Policy. Managers who are not authorized spokespersons will refer all calls regarding potentially sensitive information, to the Information Officer or appropriate designated staff.

RESPONSIBILITIES OF THE INFORMATION OFFICER

The Information Officer will be responsible for ensuring that sensitive corporate communications are appropriately reviewed prior to its release. Where appropriate, the Information Officer will consult with officers in other departments regarding new information requests that may affect their operations and/or with President/Chief Executive Officer as required.

The Information Officer will report, on a quarterly basis, to the President & CEO, Board of Directors and Senior Executive Officers on the number of requests received in the previous quarter and on the requests fulfilled.