RE: Growthfronts17 Feb 2025 17:24
Probably hiding behind this Flightman
There are some limited exceptions to the announcement obligations for impending developments or matters in the course of negotiation. An AIM company is permitted to disclose such information in confidence to various categories of persons (such as advisers or employees involved in the development or matter and transaction counterparties) provided the recipients are made aware of the requirement to refrain from dealing upon receipt of the information and who are bound by a duty of confidentiality. In addition, the AIM company must ensure that it has in place effective procedures and controls designed to ensure the confidentiality of such information in order to minimize the risk of a leak.
This
in circumstances where the issuer considers that immediate disclosure of inside information is likely to prejudice the issuer’s legitimate interests, an issuer may delay the disclosure provided that to do so would not be likely to mislead the public and the issuer is able to ensure the confidentiality of the information. Where an AIM company delays the disclosure of inside information, it must inform the FCA that disclosure of the information was delayed immediately after the information is disclosed to the public. The FCA may request that the issuer provides a written explanation of how the conditions outlined above were met.
And this
Insider lists. In order to control access to inside information, AIM companies and any person acting on their behalf or on their account are required to each draw up and maintain a list of persons who have access to inside information. Insider lists must be prepared in accordance with a prescribed template identifying each person having access to inside information and be updated promptly to reflect new people gaining, or existing insiders ceasing to have, access to inside information. Insider lists must be kept for a period of at least five years from being drawn up or updated and must be provided to the FCA upon request. AIM companies must also ensure that every person on an insider list acknowledges their obligations under the insider dealing and market abuse legislation and is aware of the sanctions that might be imposed for breaches of such legislation.
Or this maybe a strategic investment
Market soundings. If an AIM company wishes to conduct a market sounding, that is, communicate information (especially where this includes inside information) to one or more potential investors prior to the announcement of a transaction in order to gauge their interest in a possible transaction and the conditions relating to it (such as its potential size or pricing), the company must comply with certain disclosure and record-keeping requirements if it wishes to take advantage of a safe harbor permitting the disclosure of inside information during a market sounding.
Who knows????
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