Changes to the Alternative Investment Market (AIM) rules, as a result of the Market Abuse Regulations (MAR) governed by the Financial Conduct Authority (FCA), affecting how and when shares in the Company can be traded by directors, employees and certain associated family members came into effect on 3 July 2016.
Clearance to trade must now be obtained by people affected by the Code.
The LGO Share Dealing Code (”Code”) reflects these requirements and all directors and staff must be familiar with the Code and are responsible for ensuring all relevant parties are also familiar with the Code.
To trade in the Company’s shares those affected by the Code will need to follow the steps stipulated in the Code.
The following associated documents can be accessed here:
1. Request for Clearance to Deal Form, to be submitted to firstname.lastname@example.org
2. MAR Notification of Trade Form
On completion of any dealing the relevant party must notify both:
a) the Company promptly, and
b) the FCA where relevant, by submitting the MAR Notification of Trade Form (also available at www.fca.org.uk/your-fca/documents/forms/pdmr-notification-form)
a) In all cases the MAR Notification of Trade Form must be submitted to email@example.com and will be shared with the Company’s NOMAD, no later than the following business day after the date of every transaction.
In addition, the following additional information should also be provided to the Company:
i. the nature and extent of the Director’s interest in the transaction;
ii. the person’s holding in the AIM securities following the transaction; and
iii. where the notification concerns a related financial product, the detailed nature of the exposure, e.g. amount and if exercised.
b) Additionally the MAR Notification of Trade Form must be completed and submitted to the FCA for transactions in or related to the Company’s shares and worth over EUR 5,000, by no later than three business days after the date of the transaction.
The requirements of the Share Dealing Code are effective from 3 July 2016, and are subject to change as further guidance and regulations concerning share dealing become apparent.