On 24 June 2016, the Institute of Chartered Secretaries & Administrators ("ICSA"), the Quoted Companies Alliance ("QCA") and GC100 published guidance on dealing codes under MAR and submitted these to the Financial Conduct Authority ("FCA") and London Stock Exchange ("LSE") for review and comment. The guidance features a policy that explains the relevant provisions of MAR to directors and employees in an easily-digestible format.
The guidance includes a specimen code that contains clearance procedures for PDMRs and further information on the obligations of the company in relation to refusing clearance, notification of PDMR transactions and the obligations that exist with regard to PDMRs' connected persons.
The guidance also features a dealing procedures manual, which sets out the process to be followed by the company in relation to dealings.
A copy of the guidance can be accessed here (registration required):
https://www.icsa.org.uk/knowledge/resources/mar-dealing-code
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.