When does the issuer remain fully responsible under the second subparagraph of Article 18(2) of MAR for the compliance with the insider list requirements by persons acting on behalf or account of the issuer?

Are persons acting on behalf or account of the issuer (e.g. advisors and consultants) subject to the obligation to draw up, update and provide to the NCA upon request their own insider list under Article 18(1) of MAR?

Does paragraph 31 of the APMs Guidelines apply to quarterly financial figures included in ad-hoc disclosures published by issuers in accordance with article 17 of MAR when there is no requirement under the Transparency Directive (TD) to publish interim financial statements (e.g. quarterly financial statements)?

How should issuers comply with paragraphs 31 and 32 of the APMs Guidelines?

How should an issuer apply the principle of “prominence” as included in the APMs Guidelines?

What are the limits for the compliance by reference principle included in paragraph 45 of the APMs Guidelines?