“How do you track connected persons e.g. children under 18 of a director who may then turn 18 or children who were living with the director but then cease to do so – and therefore their shares do not need to be included in the director’s holding any longer? And do you make an announcement when those shares cease to be deemed part of the director’s holding?”
We ask them to confirm on appointment and as part of our six monthly review process. Any holdings by a connected person are recorded on the directors interest record clearly identified as held by a connected person. However in reality we have only had to deal with spouses holdings.
On appointment and then annually we confirm director and PDMR shareholdings and connected persons, and the registered name, flagging the need to advise of changed circumstances in the interim.
In reality, few seem to have connected person holdings (other than spouses), and for those that do we talk each through eg holdings held in trust seem to be most common.
We will in fact shortly have an announcement to make where the interest in a trust set up for a child ceases. So yes to the second part of your question.
We ask them to confirm their connected parties as part of the year end questionnaire process. Ultimately it is their responsibility.