On Nov. 12, 2018, EU ESMA issued its updated FAQs on the implementation of MAR.
- Included new question 7.10, under managers transactions, and specifically the non-applicability of the ban to transactions of the issuer on its own financial instruments.
- Whether the prohibition in MAR, art. 19(11) encompass transactions relating to own instruments even if PDMRs taking decision / bringing previous decision into practice.
- Answer: no, art. 19(11) of MAR prohibits PDMRs within an issuer, and not the issuer itself, to conduct any transactions on its own account / for the account of third party.
- Directly or indirectly, relating to the share or debt instruments of the issuer during a closed period of thirty calendar days, before the announcement of a financial report.