Lexology - practical know-how

On 3 July 2016 the AIM Rules for Companies (‘AIM Rules’) changed. The London Stock Exchange plc (‘LSE’) has amended these rules to implement changes that are required due to the EU Market Abuse Regulation (2014/296/EU) (‘MAR’) coming into force in the UK.  Many of the changes are quite technical but there are a few key points to be aware of, including some changes to the market notification requirements, new standards in relation to share dealing policies and a change to close periods.

KEY CHANGES ARE:

• the definition of close periods has been changed to align with MAR (it is now only 30 days before results);
• there is now a mandatory requirement for a share dealing policy that addresses certain minimum requirements;
• nominated advisers (‘Nomads’) are responsible for determining whether share dealing policies are “reasonable and effective”; and
• when considering whether to delay an announcement, AIM companies will need to be conscious of the MAR obligations and the separate AIM Rules obligations.
  

MAIN ACTIONS ARE TO:

• review and/or adopt a new compliant share dealing policy;
• identify Persons Discharging Managerial Responsibility (‘PDMRs’);
• train PDMRs on their dealing obligations under MAR; and
• consider forming a board committee to deal with decisions on whether to announce or not.

For more information please contact Jonathan Morris - Partner.

Jonathan is a corporate lawyer with extensive experience of advising small and mid cap-market companies on their public and private fundraisings. He acts for owner-managed businesses and corporates on M&As, and regularly advises issuers and Nomad/brokers on domestic and international AIM IPOs, secondary fundraisings and public offers. He has advised clients on structuring pre-IPO fundraisings, group reorganisations and joint ventures, and assisted UK and overseas groups with their restructurings including facilitating distributions to ultimate parents, demergers and divisions of assets as part of divorces proceedings.

Email: jmorris@thrings.com

Tel: 020 7766 5670