The ICSA, GC100 and the QCA have jointly published a guidance note on the Market Abuse Regulation, which contains a specimen of the following: (i) a group-wide dealing policy, which is designed to introduce the concept of market abuse to all group employees and directors; (ii) a dealing code split into two parts, Part A containing the clearance procedures for dealing in the company’s securities and Part B which sets out further obligations which only apply to PDMRs (persons discharging managerial responsibilities); and (iii) a dealing procedures manual for the company’s use. The dealing code and procedures manual are intended to be used together and are based on the assumption that the company is incorporated in the UK with financial instruments admitted to trading on the Main Market of the London Stock Exchange or quoted on AIM. They do not address the additional requirements under MAR which apply to emission allowance market participants. All three documents are being submitted to the FCA and the London Stock Exchange for their review and comment.
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MAR: Specimen dealing code and manual
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