Topic Information obligations for issuers Examples of persons at the issuer to be included
Article from Issuer Guidelines published by the Federal Financial Supervisory Authority
Staff working in the areas of compliance, financial control, finance, investor relations, legal and tax, and members of the ad hoc committee, works council and the economic committee are regularly included in insider projects and are thus insiders.
As a rule, members of governing bodies such as management board members regularly have access to the relevant inside information in the course of their duties and must therefore be included in the issuer’s insider list. However, the government body members are not themselves obliged to maintain their own insider list.
Executive assistants employed by the issuer must be included in the insider list if they have corresponding access to the relevant inside information. Assistants to supervisory board members must also be included if they are employed by the issuer. However, if assistants to supervisory board members are employed by the member him- or herself or by a third-party company, they are not included in the issuer’s insider list because they have no legal relationship with the issuer.
