PDMRs are defined as:

  • (a) Board members (including deputies).
  • (b) Managing Directors (including vice MDs).
  • (c) Any other senior executive with regular access to inside information and the power to make managerial decisions affecting the company’s future developments and business prospects.

The person’s position within the company is decisive, regardless of the specific information the person may have in individual cases.

PDMRs and their Persons Closely Associated (PCAs) are required to report their transactions in the company to both the financial supervisory authority and the company within three business days (MAR Art. 19). Additionally, PDMRs (but not PCAs) have a trade ban 30 days before the reporting date.

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