This manual sets out the procedures to be followed by PCI-PAL PLC (the “Company”) and its subsidiaries in relation to Dealings in Company Securities.
The Dealing Code imposes restrictions on dealings in Company Securities by PDMRs and certain employees who have been told that the clearance procedures in Part A of the Dealing Code apply to them.
The purpose of this manual and the Dealing Code is to assist the Company to comply with its obligations under the Market Abuse Regulation and to ensure that the Company has the necessary systems and procedures in place to assist its PDMRs and other employees of the Company and its subsidiaries to comply with their obligations under the Market Abuse Regulation.
The Company’s dealing procedures recognise different types of periods during which dealing restrictions apply: (i) those imposed by the Market Abuse Regulation; (ii) those that the Company has adopted for periods prior to announcements of the Company’s financial results (which will overlap with, but may be longer than, those imposed by the Market Abuse Regulation); and (iii) those which arise due to the existence of Inside Information.
The Company may be able to be more flexible in respect of Dealings in its securities that are proposed to take place during periods that fall into the latter two categories, given that the requirements of the Market Abuse Regulation may not strictly apply to prevent the relevant transaction at those times. However, the Company should take advice before deciding whether to relax the requirements set out in this document.
The defined terms clarify the meaning of capitalised words used in these procedures.
