Question 9: Concept of Prominence; Paragraph 35 and 36 of the APM Guidelines.

Date last updated: July 2017

Question: How should an issuer apply the principle of "prominence" as included in the APMs Guidelines?

Answer: As the APMs Guidelines do not define the concept of prominence, issuers should use their judgment when complying with this principle. This judgement should be made on a case-by-case basis depending on the documents where the APMs are included.

The notion of prominence is, in essence, qualitative and not merely quantitative. Therefore, counting the number of APMs and measures directly stemming from financial statements may not suffice. When applying its judgement, the issuer should ensure that the measures stemming from financial statements are not displayed with less prominence, emphasis or authority than APMs.

The following factors, among others, could help issuers when exercising their judgement:

• Attention paid to APMs in comparison with measures directly stemming from financial statements;

• Location of APMs within the document;

• Frequency of use;