RE: Appalling lack of communication as usual.27 Nov 2025 12:46
The "Secret" Rule (AIM Rule 11 & MAR Article 17)
AIM Rule 11 says companies must announce everything immediately. However, MAR Article 17 allows them to delay this announcement if:
It is to protect a legitimate interest (e.g., negotiating a deal).
They can guarantee strict confidentiality.
They are logging everyone who knows.
2. The "Log": Is there an audit trail?
Yes. It is called the Insider List (MAR Article 18).
This is not a casual notebook; it is a legally binding digital register that the company must maintain. If the FCA (Financial Conduct Authority) investigates a leak, they will demand this list.
What exactly is logged?
The level of detail is invasive to ensure accountability. For every person (Director, Buyer, Banker, Lawyer) who knows about the deal, the log must contain:
Date & Time: The exact minute (e.g., 14:02 GMT) they gained access to the info.
Reason: Why they need to know.
Personal Data: Their home address, personal mobile number, and National Insurance number.
Why this matters: If a "prospective buyer" tells their brother to buy shares, the FCA uses this log to link the personal phone numbers and trading accounts.
3. How do I know they are working on my behalf?
Since you cannot see the Insider List (it is confidential to prevent leaks), you rely on two "Gatekeepers":
A. The Nomad (AIM Rule 31)
The Rule: AIM Rule 31 states that the company must have sufficient systems to comply with the rules and must consult their Nomad (Nominated Adviser).
The Protection: The Nomad is the regulator's eyes and ears. If the company is talking to buyers, the Nomad is usually in the loop. If the Nomad suspects the Directors are doing a "dirty deal" or leaking info, they can threaten to resign. If a Nomad resigns, the company's shares are suspended immediately. This gives the Nomad immense power to keep Directors honest.