The Market Abuse Regulation (MAR) comes into force and effect on
3 July 2016, replacing the existing market abuse regime. The new
regime would survive (at least for a period) a Brexit vote later
this month should that occur, so it is important that all AIM
companies are aware of the impact and consequences of MAR.
Although some of the changes are quite subtle, there are a few
key changes that are likely to impact AIM companies which are
Dealings by persons discharging managerial responsibilities
Various new rules regarding disclosure and dealings during
AIM companies must have a share dealing code
A broader application, as not just directors of AIM companies
will be covered
New close periods of different durations to current
Ensure suitable processes are in place
Adopt or revise the share dealing code
Train PDMRs on the new regime and processes
Existing AIM rules on disclosure are likely to remain but to
sit alongside similar, but not identical, disclosure obligations
New MAR rules (similar but not identical to the existing AIM
rules) regarding the delay of disclosure of inside information
New requirement to keep insider lists, in a prescribed
Ensure suitable procedures are in place
Prepare an insider policy and prepare insider lists in the
Consider establishing a committee to handle the dissemination
and delay of disclosure of inside information
Market Soundings (e.g. in relation to possible
fundraisings, transactions etc.)
New rules regarding the disclosure of information in relation
to possible fundraisings, transactions etc
New rules on record keeping of disclosures
Train any employees who are involved in market soundings
Ensure record keeping procedures are in place
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.
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