Share Dealing Code
The Share Dealing Code (the “Code”), set out below, has been adopted by the board of GlobalData plc (“the Company”). The Code incorporates the rules on director’s dealings in securities in the form included in the AIM Rules of London Stock Exchange plc (the “AIM Rules”): extracts from the relevant AIM Rules are set out in Appendix 1. It sets recognized standards of good practice for dealings in shares and other securities of the Company admitted to trading on AIM (“AIM securities”) and should provide general protection against misinformed criticism, for the benefit of both the Company and individual directors and employees. Appendix 2 contains additional information relating to the Code in a question and answer format: Appendix 2 does not form part of the Code.
It is important that those proposing to deal in the Company’s AIM securities are aware that, in addition to the Code, the laws of Great Britain impose restrictions on “insider dealing” currently contained in the Criminal Justice Act 1993 and “market abuse” in the Financial Services and Markets Act 2000. Compliance with the Code would not be a defense against breaches of the law, which are punishable by imprisonment and/or unlimited fines. A summary of the relevant legislation is set out in Appendix 3 to the Code.
Additional general disclosure obligations exist for Directors of the Company under the AIM Rules (a copy of the relevant AIM Rules is set out in Appendix 4).
- All directors of the Company from time to time and all applicable employees (within the meaning of the AIM Rules) of the Company from time to time must comply with the provisions of the AIM Rules in relation to dealings in the Company’s AIM securities. The Company has also decided to extend the times during which dealing is restricted beyond the requirements of the AIM Rules so that dealing is also restricted at any time when it has become reasonably probable that unpublished price-sensitive information relating to the Company’s AIM securities will be required to be announced by the AIM Rules.
- Each person to whom the Code applies must obtain written clearance before any dealing (including any off market dealing) in the Company’s AIM securities takes place, other than dealings not restricted by the Code. To obtain clearance to deal, applicable employees (other than directors of the Company) should complete and sign the Application to Deal form (copies obtainable from the Company Secretary) and return it to the Company Secretary. The Company Secretary shall, where appropriate, refer the matter to the Company’s nominated adviser. A director of the Company or any subsidiary undertakings must not deal without advising the Executive Chairman (or one or more other directors designated for this purpose) in advance and receiving clearance. The Executive Chairman shall, where appropriate, refer the matter to the Company’s nominated adviser. In his own case, the Executive Chairman, or other designated director, must advise the board in advance at a board meeting, or advise another designated director, and receive clearance from the board or designated director, as appropriate. Each director and applicable employee must not deal until he or she receives a signed clearance. The Company shall, for a reasonable period, retain records of all clearances granted.
- The Company applies the Code equally to dealings in the Company’s AIM securities to be made by or on behalf of any person within the director’s or applicable employee’s family. (notwithstanding that the AIM Rules may not require this), and directors and applicable employees are required to take reasonable steps to ensure that members of their families comply with this Code.
Extracts from the AIM Rules of London Stock Exchange plc.