RE: Trades17 Jul 2025 19:05
Bella - don’t think directors can buy or sell during a closed period :
Key Points on Closed Periods:
1. Definition of a Closed Period:
• A closed period is typically the time leading up to the announcement of a company’s financial results or other significant price-sensitive information. For example, under the UK MAR, a closed period is often the 30 days before the announcement of interim or annual financial results.
• The exact duration and definition may vary by jurisdiction or company policy.
2. Restrictions During Closed Periods:
• Directors (and other persons discharging managerial responsibilities, or PDMRs) are generally prohibited from buying, selling, or otherwise dealing in the company’s shares during a closed period, as they may possess inside information that could give them an unfair advantage.
• This restriction applies to transactions for their own account or for the account of a third party.
3. Exceptions: There are limited circumstances where directors may be allowed to deal during a closed period, such as:
• Exceptional Circumstances: Directors may be permitted to trade in exceptional cases, such as financial hardship, but this typically requires prior approval from the company’s board or a designated authority.
• Pre-Approved Transactions: Certain transactions, like those under a pre-existing share trading plan (e.g., a Rule 10b5-1 plan in the U.S.), may be allowed if set up outside the closed period and executed automatically without the director’s discretion.
• Non-Discretionary Transactions: Transactions like dividend reinvestment plans or employee share schemes that are not influenced by the director’s discretion may be permitted.