The requirements on management of Persons Discharging Managerial Responsibilities (PDMRs) (art. 19), including;

The sanctions for incorrect handling of the requirements for PDMRs (article 19) covers, amongst others, the following items:

  • Failure to create or update the list of PDMRs without delay
  • Lack of information to PDMRs with regards to MAR
  • Unnecessary delay in submitting the list to the NCA
  • Lack of information from a PDMR to their close associates with regards to MAR
  • the requirements on investment recommendations (art. 20).

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