Set up an insider list to delay disclosure of inside information

Create a new insider list

To open a new insider list, click the new list button.

Basic information

1. Enter a list title. Note that this title will appear in the email sent to all insiders, so avoid including any sensitive information.

2. Under inside information, specify what the information is concerning in further detail. For example, 'Purchase of competitor X'. Short description of the project. This will not be visible to the insiders. Only visible to the admin and a part of the documentation of the insider list.

3. The list created field is auto-populated with the current date and time. Make sure that the correct date and time for when the information was identified is entered. 

4. Add the person who is responsible for the delayed disclosure; this is who is responsible as set out in article 4.1(b) of implementing regulation 2016/1055.

5. Set your reminder frequency. The default is one day, which means that the insiders will receive daily reminders until they complete their form. This can be customised.

6. Add additional notes if needed.

7.  Assign an admin group that will access and manage the list.
8. After entering all the information, click Next at the bottom of the page to proceed to the next step.
     
   

   

Delay of disclosure details

1. Tick the box for yes, public disclosure is being delayed
   
2. Fill in the Date delayed field with date and time when the decision to delay the disclosure of inside information was made and the Date of expected disclosure field with date and time when the company is likely to disclose the information
   
3. Answer all the required questions. If your answer is not compliant with MAR’s requirements, the system will tell you that you’re not allowed to delay the disclosure.
4. Once the relevant sections are complete, click on Next to move on to the next step.
   
   

Delay of disclosure argumentation (Optional)

This section allows you to input and store your explanation of how the criteria for delaying disclosure, as required by Article 17.4 of MAR, are fulfilled. You may enter this information now or complete it later in the list settings. You may also upload supporting files in the settings page.

Overview

This page provides an overview of your list. If any information is missing, click Previous at the bottom of the page to go back and make changes. If everything looks correct, click Create list to complete the process.

Add insiders

Now that your list is created, you can start adding insiders to the list.

1. Press add person.
2. Enter the email address(es) of the person(s) you want to add. You can also add a contact group name. Contact groups can be created under the contacts tab.
3. Enter the date and time when the insider(s) received the information.
4. Choose which email to send to the added person(s): 
   1. Send email with notice of obligations and link to form (to collect confirmation and personal details). 
   2. Include a request that the insider must keep a sub-list. 
   3. Send custom email instead of using the standard template. This will allow you to edit the email before sending it.
   4. Uncheck all boxes to avoid triggering an email to the insider.