DEALING MEMBERS?INSIDER DISCLOSURE OBLIGATIONS
Further to our circular with reference NSE/LARD/BDR/CIR1/17/03/08 dated 8 March 2017, on the above subject matter, Dealing Members are hereby reminded of the following provisions of the Rulebook of The Exchange, 2015 (Dealing Members?Rules), pertaining to Insider transactions and the disclosure obligations of Dealing Members:
i. Rule 1.14: Disclosure Obligation:
Every Dealing Member is required to deal with The Exchange in an open and cooperative manner, and shall disclose any matter relating to the operations of the firm on which The Exchange would reasonably expect notice. The foregoing obligation shall be in addition to all financial disclosures to The Exchange.
ii. Rule 1.24: Definitions:
Insider means a person who has inside information through being a director, employee or shareholder of an issuer of securities traded on The Exchange to which the inside information relates; or who has access to such information by virtue of his employment, office or profession; or such person knows that the direct or indirect source of the inside information was any of the aforementioned persons.
Inside Information means specific or precise information, which has not been made public and which is obtained or learned as an insider; and if it were made public would be likely to have a material effect on the price or value of any security listed on a regulated market.
iii. Rule 17.21(c): Confidentiality of Information:
A Dealing Member is obliged to disclose to The Exchange any share purchases for a client which is five per-cent (5%) and above, of the share capital of the company.
In addition, the attention of Dealing Members are hereby drawn to the following provisions that further define an Insider:
(i) Section 315 of the Investments and Securities Act, No. 29, 2007 (ISA), provides that an Insider is:
(a) any person who is or is connected with the company in one or more of the following capacities- (i) a direc