The issuer must keep a list of all PDMRs (Persons Discharging Managerial Responsibilities) and PCAs (Persons Closely Associated). This requirement is separate from the insider logbook obligations.
List Format and Content Requirements
- There is no requirement for a special format for the list.
- The list must include:
- (a) The name and appropriate position of each PDMR.
- (b) The names and business names of their PCAs, clearly indicating who is associated with whom.
Issuer Responsibilities Regarding PDMRs and PCAs
The list of PDMRs and PCAs is not public.
It is not the responsibility of the issuer to verify the association or whether individuals have been notified.
The issuer is also not responsible for taking action regarding transaction notifications received by the issuer.
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