Do the APMs Guidelines apply to financial measures such as financial ratios calculated using exclusively figures directly stemming from financial statements?

Which are the rules to calculate the price of options granted for free to managers or employees for the purpose of the notifications and disclosure of managers’ transactions under Article 19 of MAR?

Can both fields 10 and 11 be populated with the same value where the request for admission to trading and the admission to trading takes place on the same day?

In some cases, the time of the request and of the admission is not known, e.g. when the instrument was listed far in the past or when the request was submitted by postal service. In such cases, would it be possible to populate fields 10 and 11 with a default time?

What should be populated in field 10 (Date of request for admission to trading) and field 11 (Date of admission to trading or date of first trade) in the cases where the instrument was listed far in the past, e.g. when the MIFID I rules were not yet applicable and the concept of Regulated Market had not yet been introduced?