In order for DC&P to provide reasonable assurance that information required by securities legislation to be disclosed by an issuer is recorded, processed, summarized and reported within the required time periods, DC&P should generally include the following components:
(a) written communication to an issuer’s employees and directors of the issuer’s disclosure obligations, including the purpose of disclosure and DC&P and deadlines for specific filings and other disclosure;
(b) assignment of roles, responsibilities and authorizations relating to disclosure;
(c) guidance on how authorized individuals should assess and document the materiality of information or events for disclosure purposes; and
(d) a policy on how the issuer will receive, document, evaluate and respond to complaints or concerns received from internal or external sources regarding financial reporting or other disclosure issues.
An issuer might choose to include these components in a document called a disclosure policy. Part 6 of National Policy 51-201 Disclosure Standards encourages issuers to establish a written disclosure policy and discusses in more detail some of these components. For issuers that are subject to National Instrument 52-110 Audit Committees (NI 52-110), compliance with the instrument will also form part of the issuer’s DC&P design.