I'm going nowhere25 Nov 2025 07:45
The exact statement:
“Potential partners who have expressed an interest in P140 range in size and scope and include a number of top ten global Pharma companies. A number of parties have signed Confidential Disclosure Agreements.”
This contains two factual claims, both of which must be verifiable.
✅ 1. Claim #1: “Top ten global Pharma companies have expressed interest.”
This means:
They have been in communication
There has been some level of engagement
A top 10 Pharma (by revenue) has confirmed interest in learning more
It is documented internally (emails, minutes, call notes)
To regulators, “expressed interest” cannot mean:
“We hoped they’d be interested,” or
“We sent them a brochure but they never replied.”
It must be actual, evidenced interest.
If no top 10 pharma had genuinely engaged, this would be misleading the market.
✅ 2. Claim #2: “A number of parties have signed Confidential Disclosure Agreements.”
This is a binary, testable statement.
You either:
have signed CDAs
OR
you don’t.
If the company states this in an RNS, the NOMAD (Nominated Adviser) would normally:
request proof
review the actual CDA documents
make sure the number and companies match the wording
confirm the statement is supportable
NOMADs must sign off on every RNS for AIM or small-cap companies.
They do not allow unverified claims.
If CDAs were not signed, this would be a blatant breach of:
UK Market Abuse Regulation (MAR)
AIM Rule 11 / Disclosure Rules
FCA Conduct of Business rules
Consequences could include regulatory investigation, fines, share suspension, CEO dismissal, etc.
🎯 Key point: The CEO is not allowed to exaggerate or “spin” this.
The rules don’t allow “big pharma interest” to be used as hype.
If they say:
“top 10 pharma interest”
“CDAs signed”
these must be factually, documentably true at the date of release.
Even something like:
overstating how many parties have expressed interest
or implying engagement where only superficial contact exists
…can breach market rules.
📌 So is this acceptable wording?
Yes — as long as it is true.
It’s a completely standard way to update the market on partnering progress.
Many biotechs use similar language when multiple companies are exploring licensing discussions.
❗But if it were false?
If any part of it were knowingly untrue, it would be considered:
⚠️ Market manipulation through misleading statements
One of the most explicitly prohibited actions under UK MAR.
Sanctions could include:
Enforcement by FCA
Public censure
Personal fines
Disqualification as a director
Civil legal action from shareholders
In extreme cases, criminal charges for fraud
This is why NOMADs are extremely cautious about approving this type of language.
⭐ Conclusion
The statement is:
legitimate corporate language
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