ESMA_QA_2303
10/10/2024
Subject Matter
Application of a new exception to PDMRs’ general prohibition to trade during the close period
Original question
Does Article 19(12a) of MAR require issuers to expressly allow their PDMRs to trade during a closed period in the case of transactions or trade activities that do not relate to active investment decisions, that result exclusively from external factors or actions of third parties, or that are based on predetermined terms?
Status: Forwarded to EC/Public Consultation/Other
Additional Information
Level 1 Regulation
Market Abuse Regulation (MAR) Regulation (EU) No 596/2014 - Market Intergrity
Additional Legal Reference
Article 19 (12a) of MAR as introduced by the Listing Act
Topic
Managers' transactions