Based upon a recent change in procedures by the Portuguese Securities
Market Commission (“CMVM”), companies that passport an EU Prospectus
into Portugal for an ESPP offering now must report the results of the
offering upon its conclusion to the CMVM.
The CMVM has not prescribed any particular format for the report or
established any statutory deadline, and companies can simply submit
a short letter that references the number of shares that were purchased
by employees residing in Portugal as soon as practicable upon conclusion
of the offering.