Compass Diversified Holdings (NYSE: CODI)

Regulation FD Disclosure Policy

Compass Diversified Holdings, Compass Group Diversified Holdings LLC (collectively, the "Company") and Compass Group Management LLC (the "Manager") are committed to the fair disclosure of information about the Company consistent with the Securities and Exchange Commission's Regulation Fair Disclosure ("Regulation FD"). For purposes of this policy, "public disclosure" means filing or furnishing a Form 8-K with the Securities and Exchange Commission (SEC), or by disseminating information through another method (or combination of methods) of disclosure that is reasonably designed to provide broad, non-exclusionary distribution of the information to the public. The Company provides public disclosure through various means including publicly noticed Webcasts, SEC reports, and press releases. It is the Company's policy to maintain an active and open public dialogue with shareholders, institutional investors, broker/dealers, and sell-side analysts (collectively, "Securities Market Participants"), that provides full, fair, accurate, timely and understandable disclosure of the Company's historical performance and future prospects in accordance with generally accepted accounting principles, and with the rules and regulations established by the SEC. The Company further believes that the market for its securities is best served when its strategies, business strengths, risks, and growth opportunities are publicly articulated.

It is the Company's policy to comply with all periodic reporting and disclosure requirements, including Regulation FD. It has been, and continues to be, our practice to disclose material information about the Company publicly and timely, not selectively.

The Company has established the following guidelines to ensure compliance with Regulation FD, and avoid selective disclosure of material non-public information.

The Company will post this policy statement on its website at www.compassdiversifiedholdings.com and update it as necessary to ensure that Securities Market Participants are informed about the Company's disclosure policy.

  1. Persons authorized to communicate on behalf of the Company to Securities Market Participants are limited to the Chairman, the Chief Executive Officer, the Chief Financial Officer and Counsel.


  2. In addition, the Chief Financial Officer, Counsel and such members of such Chief Financial Officer's staff as are designated by such Chief Financial Officer are authorized to communicate with shareholders and beneficial owners in response to inquiries regarding shareholder accounts and other administrative matters.


  3. Other officers of the Company and/or the Manager may communicate, from time to time, with Securities Markets Participants, subject to the approval of the Chief Executive Officer. Such authorized representatives are not authorized to communicate business or financial information about the Company that is material non-public information, except through Company-approved public disclosure.


  4. It is our policy that, except as specified under (a), (b) and (c) above, representatives of the Company shall not communicate with Securities Market Participants, and should refer all questions to the Chief Financial Officer, Counsel or to any external Investor Relations service provider identified on the Company's website.


  5. The Company believes that one-on-one communications with Securities Market Participants can be a valuable component of its Investor Relations program. Except as provided in clauses (a) and (b) above, Counsel or a representative of the Investor Relations Group shall participate in such conversations. During such conversations, authorized representatives may discuss information the Company has previously publicly disclosed, non-material information, and generally known Company or industry-related information.


  6. In order to ensure that complete and accurate information is obtained, Securities Market Participants should direct all inquiries regarding the Company's financial condition, results of operations, strategies and other similar matters, to the Company's Investor Relations Group. Statements by employees or agents who are not authorized representatives of the Company should not be relied upon.

Neither the Company nor its representatives shall disclose material non-public information (as defined in the Company's Policy Regarding Insider Trading, Tipping and Other Wrongful Disclosures as from time to time posted on the Company's website) to any person or entity under circumstances in which it is reasonably foreseeable that the person or entity will purchase or sell the Company's securities on the basis of the information.

  1. We will hold quarterly investor conference calls open to the public and media, and provide public notice about the call through a media release, by electronic distribution, posting on at least one well known public financial information website, and the Company website. We will furnish our quarterly or annual written earnings release to the SEC on a Form 8-K as required by the Form 8-K reporting rules.


  2. Playback of the conference call will be provided on the Company website after the conference call.


  3. When we provide guidance relative to Company financial goals, all guidance, and changes to or affirmations of guidance, will be provided through public disclosure.


  4. As needed, from time to time, we will hold topical investor conference calls open to the public and media, and provide public notice about the call through a media release, by electronic distribution, posting on at least one well known public financial information website, and the Company website.


  5. Following any investor call or public comment, we will not provide new material information or elaborate in a material way beyond what was covered during the call or public comment.

If requested, we will review draft analyst reports and model inputs of actual results for accuracy on publicly disclosed facts only.

  1. We will use the safe harbor guidelines for forward-looking information as part of individual, group, and investor conference communications formats.


  2. The Company will participate in securities firm-sponsored and other investor conferences only to the extent that adequate prior public notice is given. It will be our practice to issue media releases in conjunction with the Company's major presentations scheduled during the year, and to post those presentations on our website.


  3. The Company will participate in other forums at which Securities Market Participants could be present, including industry seminars, trade shows, employee, retiree, annual shareholder meetings, and meetings with commercial partners that are shareholders. We do not intend to disclose any material non-public information during these meetings.

Although the Company recognizes that Regulation FD does not apply to communications with the media, it is the Company's policy to publicly disclose material information before discussion with individuals representing the media.

All inquiries regarding the provisions or procedures associated with this policy should be addressed to the Investor Relations Group at: www.compassdiversifiedholdings.com.