On 13 July 2016, ESMA published an updated version of its Q&A on MAR on closed periods, i.e. where persons discharging managerial responsibilities are prohibited from dealing in shares and debt instruments of the issuers, unless certain specified circumstances are met. ESMA provides that the announcement of preliminary financial results agreed by the management of the issuer constitutes the announcement marking the end date of a closed period under the MAR regime. ESMA clarifies that where the information announced changes after the publication, a closed period will not be triggered but the event should be addressed in accordance with Article 17 of MAR.
The updated Q&A can be accessed here:
https://www.esma.europa.eu/sites/default/files/library/2016-1129_mar_qa.pdf
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