“Do companies impose a formal close period prior to the release of their Interim Management Statements and do they have a bespoke narrower insider list or is the list of insiders the same as for the interim and annual results; or do they just review requests to deal prior to the release of the IMS on a case by case basis factoring in the content of the announcement?”
We do impose a close period ahead of our IMS. We determine a date for its commencement based on a judgement of when our consolidated numbers become accessible, so it varies slightly each occasion. Those prohibited from dealing are the same subset of our insider list that we use for our half-year and full-year results.
We impose a c. 5 working day closed period prior to the release of an IMS. As mentioned by others, our brokers advised that this was good practice even if not a legal requirement. We apply this to the fairly wide Insider List to which our normal dealing code applies.
We do not impose a formal close period before IMS announcements but as stated by others, if there is unpublished price sensitive information which is available through the draft IMS we would advise those aware of it that they could not deal.
We do not operate a formal close period in advance of each IMS, consequently there are no insider list implications.
IMSs generally tend to be along the lines of “trading in accordance with expectations”. Any event deemed to be unpublished price sensitive information should of course be announced immediately, rather than be wrapped into an IMS.
Similar to an earlier respondent, we do no operate a formal close period ahead of an IMS. Normally there isn’t any significant new information contained in it. Those involved in the production of the IMS are covered by our insider dealing code.
We do no operate a formal close period ahead of an IMS and there is not normally any significant new information contained in it. Anyone involved in the production of the IMS is covered by our insider dealing code and required to obtain permission to deal prior. During the period immediately prior to the release of the IMS any request from this group would be subjected to increased scrutiny and it is possible that they may not be granted permission.
For IMSs we impose a close period of approximately 7/8 working days (the second Friday prior) prior to announcement on a narrower insider list than that for half year and annual results announcements.
We do no operate a formal close period ahead of an IMS, there is no requirement to do so. The usual rules of dealing whilst in possession of insider knowledge apply however and directors, PDMRS and anyone else involved in the drafting of an IMS would not be allowed to deal in the run up to its issue.
We treat an IMS like the prelim and interim results announcement, but just have a 2 week close period prior to announcement. This is obviously not a requirement under the listing rules (and legal advice we received said it was not required), but was something suggested by our broker (Caz) and the Chairman agreed with. We just thought it was a practical approach which gave clarity and certainty rather than having to make what can at times be difficult judgement calls on a case by case basis.
IMSs will normally be dependent on directors’ view on Q1 or Q3+ performance, so for December year end companies I would have thought mid-April and mid-November, or possibly a few days earlier, to impose close period. As close period is shorter for IMS for most purposes would restrict everyone on broader insider list, but might be more pragmatic for people below PDMR level with maturing share awards or expiring share options with tax etc to pay.
We do not have a formal close period prior to the release of our IMS. The IMS sends out the message “business as usual” to our analysts and the market. If we became aware of information likely to affect the market our obligation would be to announce immediately and not wait for the IMS.
In terms of insider list admin – we do have a “permanent” insider list made up of those with access to important information (eg Company Secretariat, Investor Relations, Financial Controller) who would need to seek clearance before dealing at any time during the year. This list is tightly controlled with only a small number of employees on it.
Other insider lists are compiled according to project – the annual report list would be wider to encompass those in our External Affairs team for example.
We always review clearance to deal forms on a case by case basis in any event and even more scrutiny is given to Directors and PDMRs wishing to deal throughout the year.
We have a “working” close period of 2 weeks prior to an IMS which is applied to the usual PDMR list. This is, of course, wholly without prejudice to any applicable prohibited period.
For IMS and trading updates we impose a close period of 5 working days prior to announcement on a narrower insider list than that for half year and annual results announcements.
We regard those covered by the Model Code as being in a formal close period when the draft IMS is sent out for comments about a week before its release. The standard insider list is the same. They are informed of the close period by the Company Secretary. Informally, if we believe there is a reason not to deal in shares just outside this period, given the impending IMS, we would turn down requests, and ask them to wait.