Navigating Market Abuse Regulation (MAR) is essential for issuers in the EU and UK, especially for those defined as PDMRs under the regulation. To help PDMRs stay on top of compliance and avoid any missteps, here are seven practical and easy-to-follow tips.
- Understand the definitions and scope: Make sure you and all PDMRs within your organization fully understand who qualifies as a PDMR and the responsibilities this entails. This includes being aware of the types of transactions that must be reported and the entities affected by these rules.
- Educate and train PDMRs: Regular training sessions for PDMRs on the Market Abuse Regulation (MAR) requirements will be worth the effort. This training should cover all aspects of the regulation, including the necessity for timely disclosure of personal transactions, insider trading laws, and the consequences of non-compliance.
- Implement robust internal policies: Develop and enforce internal policies that define the procedures for reporting transactions and managing insider lists. These policies should include clear guidelines on what information needs to be disclosed, how to submit it, and within what timeframe.
- Maintain accurate and updated insider lists: Keep a detailed and up-to-date list of all persons who have access to inside information. This list should be readily accessible and updated as soon as there's a change in the status of insiders or relevant information.
- Regularly review and monitor transactions: Implement systems to regularly review and monitor the trading activities of PDMRs to ensure that all transactions are reported in compliance with the regulations. Automated systems can help track transactions in real time and alert compliance officers to any potential issues.
- Set up a compliance calendar: Maintain a compliance calendar that highlights all key reporting deadlines and corporate events that might influence trading decisions. This helps PDMRs avoid inadvertent breaches by making them aware of closed periods and other sensitive times when trading is restricted.
- Encourage a culture of compliance: Foster a culture of transparency and compliance within the organization. Encourage PDMRs to approach the compliance team with any questions or concerns about potential conflicts of interest or ambiguities in regulation interpretation. This proactive approach can prevent inadvertent breaches of regulations.
Managing Persons Discharging Managerial Responsibilities (PDMRs) under the Market Abuse Regulation (MAR) involves navigating a complex regulatory landscape. Below are some common questions and best practices to ensure compliance.
