Market Abuse Regulation (MAR) – Insider Information
MAR & Market Abuse Act: Insider Information Protocols for Nordic IR Websites
The EU MAR aims to uphold market integrity by outlawing insider trading and them is use of privileged information. Under MAR (and Sweden’s implementing legislation), “inside information” is any non-public detail that an investor would likely use in deciding to buy, sell, or hold a security.
- Definition & Scope of Inside Information
– Includes financial results, M&A plans, major contracts, or changes in strategic direction.
– Must be precise, reliable, and non-public at the time of disclosure. - Required Procedures
– Insider Lists: Maintain up-to-date lists of employees and third parties with access to inside information, ensuring timely creation and updates.
– Information Barriers: Implement “Chinese walls” between teams (e.g., M&A vs. IR) to prevent inadvertent leaks.
– Confidentiality Agreements: Require all individuals on insider lists to sign NDAs that clearly define prohibited actions. - Timely Public Disclosure
– Immediate Publication: Once inside information is confirmed, it must be released “as soon as possible,” minimizing any window for unequal access.
– Uniform Channels: Simultaneously publish on your IR website and approved news distribution services to ensure equal access. - Sanctions & Enforcement
– Non-compliance can lead to administrative fines, criminal penalties, and reputational damage.
– Supervisory authorities may also impose trading suspensions or require corrective disclosures.
By embedding MAR-compliant workflows into your IR operations, comprehensive insider lists, clear confidentiality rules, and automated publication pipelines, you protect your company from sanctions while preserving investor confidence.