“We are keen to know what, if anything, other companies do in relation to close periods for trading updates.
We report at full and half years and provide Q1 and Q3 trading updates. We want to know whether other companies enforce close periods for trading updates or whether they just restrict certain people from dealing during those periods.”
We apply a close period for a reduced insider list for approx 10 days prior to relaese of an IMS. This is restricted to those wha are aware of the content of the IMS.
For the Interim Managemnt Statements we do have a close period for a reduced Insider List, just the people who have access to the contents of the IMS itself. It starts approx 10 days prior to announcement.
We ask PDMRs and any other insiders to regard themselves as being in a prohibited period from two weeks before an IMS or pre-close trading update. This means that permission to deal would not be given during that time.
In a previous FTSE 250 life, the view was taken that those drafting the statement should not deal and PDMRs from the point they received sight of the draft (normally one week before its release).
We apply usual close periods prior to our IMS announcements to avoid confusion. It’s what we did previously when we did full quarterly results so it is the system with which our executives were familiar so we stuck with it. While you could argue it’s somewhat overkill we considered it was the prudent approach to take.
We apply a close period prior to the publication of an IMS. This starts from the 1st of the month during which the IMS wil be released, given that any financial information provided will be taken from results up to the close of the prior month.
We apply a two week close period prior to the quarterly IMS.
We deem the two week period prior to the announcement of our quarterly production report/IMS as a close period.
We apply a close period to the quarterly IMS just so there is no confusion.
We tend to apply the practice of treating the trading update as if it triggers a close period, just to be on the safe side.