Which are the rules to calculate the price of gifts, donations and inheritance for the purpose of the notifications and disclosure of managers’ transactions under Article 19 of MAR?

When calculating whether the threshold triggering the notification obligation under Article 19(1) of MAR is reached (5.000 EUR or 20.000 EUR), should the transactions carried out by a person discharging managerial responsibilities (PDMR) and by closely associated persons to that PDMR be aggregated?

ESMA’s Guidelines on Alternative Performance Measures (ESMA/2015/1415) apply to APM’s disclosed by issuers or persons responsible for the prospectus when publishing regulated information or prospectuses on or after 3 July 2016, cf. paragraph 5 of the Guidelines. Given that a prospectus can be formed by a combination of a registration document and a securities note, and a summary where applicable, and that prospectuses or base prospectuses can incorporate by reference the information contained in a previously approved registration document, do the Guidelines apply:

- to a registration document containing APMs which was published before 3 July when that registration document is combined with a securities note published on/after 3 July?

- to a registration document (or prospectus) containing APMs which was published before 3 July when the information contained in that registration document is incorporated by reference into a prospectus or base prospectus published on/after 3 July?

- to a supplement containing APMs published on/after 3 July when the prospectus or registration document was published before 3 July?

Does trading activity in C6 contracts which takes place on OTFs after 3 January 2018 need to be counted towards the ancillary thresholds prior to that date?

Do all legal entities that deal in commodity derivatives within a financial group need to be individually authorised as investment firms?