What is a closed period under MAR?

Under the Market Abuse Regulation (MAR), a closed period is the 30 calendar days before the announcement of an interim financial report or a year-end report during which a PDMR must not conduct transactions on their own account or for a third party, directly or indirectly, in the issuer’s shares, debt instruments, derivatives, or other linked financial instruments.

A PDMR is a person discharging managerial responsibilities, such as: - a director - or a senior executive who regularly has access to inside information and power to make managerial decisions affecting the issuer’s future developments and business prospects

The rule is designed to reduce the risk of trading while senior managers may possess unpublished financial information ahead of results.

There are limited exceptions. In certain narrowly defined cases, the issuer may permit trading during a closed period, for example: - in exceptional circumstances such as severe financial difficulty - for certain employee share scheme transactions - or for transactions where there is no active investment decision or no real change in beneficial interest

Even where an exception may apply, the general prohibition on insider dealing still remains fully in force.