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Topic Information obligations for issuers Updating the list

Article from Issuer Guidelines published by the Federal Financial Supervisory Authority

Under point (b) of Article 18(1) in conjunction with paragraph (4) of the MAR, the insider list has to be updated without undue delay when there is a change in the reason for including a person, if a person who was previously not included has access to inside information or if a person included in the list ceases to have access to the relevant inside information. Under the second sentence of Article 18(4) of the MAR, each update must specify the date and time when the change triggering the update occurred.

The obligation to update the insider list ends when there is no longer any inside information. This is the case when the information has been made public or if the inside information no longer applies or the project has been terminated before its scheduled completion. In this case, the date when the ad hoc disclosure is made public or the date of the end of the project must be specified. For individual employees, the obligation to update the list ends when the employee leaves the company. The date of leaving must be entered in the list. Absences due to vacation or short-term sick leave of persons included in the list are not a reason to update the list.

The insider list can also be amended over and above the requirements of Article 18 of the MAR – in the sense of a correction rather than an update – if certain personal data changes, for example a surname or a personal home address or phone number.

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