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In response to the coronavirus (COVID-19) pandemic London Stock Exchange announced on 26 March 2020 and 9 June 2020 temporary measures for reporting deadlines in relation to the publication of audited annual results and half-yearly reports that are required by the AIM Rules for Companies (“AIM Rules”). This Inside AIM confirms that these temporary measures remain available for AIM companies until further notice of an orderly transition back to standard reporting periods. For ease of reference we set out in this Inside AIM the protocol for an extension to an AIM company’s reporting deadline.
An AIM company seeking an extension of its reporting deadline for its annual audited accounts pursuant to AIM Rule 19 can apply to AIM Regulation for an extension of up to three months. The request for the extension must be made by the AIM company’s nominated adviser and submitted prior to the current AIM Rules reporting deadline. AIM companies should continue to refer to guidance published by Companies House in respect of the temporary changes to UK filing requirements and note that at the moment the automatic extension ends for any filing deadlines that fall on 6 April 2021 or later1. Thereafter, an application will need to be made to Companies House for filing deadline extensions.
For an AIM company wishing to utilise the additional one month period for its half yearly report, it must notify its intention to do so, via a RIS, prior to its reporting deadline under AIM Rule 18. The company’s nominated adviser must inform AIM Regulation of this separately.
We also note the joint FCA and FRC statement dated 27 January 2021 reminding listed companies extended financial information timelines continue to apply. London Stock Exchange welcomes this practical support for listed companies. The statement can be found here.
Coronavirus – Financial reporting deadlines
Date: 27 January 2021
1 See paragraph 1.7 https://www.gov.uk/government/publications/the-companies-etc-filing-requirements-temporary-modifications-regulations-2020/temporary-changes-to-companies-house-filing-requirements
This Inside AIM sets out temporary relief for AIM companies who choose to use the Accounting for Lease Modifications (Amendment to IFRS 16 – Covid-19-Related Rent Concessions) before adoption by the EU (“IFRS 16 Amendment”).
London Stock Exchange (the “Exchange”) refers AIM companies and nominated advisers to the FRC statement providing background as to the reasons for the IFRS 16 Amendment and notes the FRC’s confirmation that it will not pursue regulatory action where issuers take advantage of the IFRS 16 Amendment, prior to it being adopted by the EU (“FRC Statement”). See link.
We welcome the FRC’s statement and appreciate the practical difficulties AIM companies may face in applying the existing IFRS 16 lease modifications requirements to Covid-19-related rent concessions. For the purpose of the financial reporting requirements under the AIM Rules for Companies (AIM Rules 18 and 19), the Exchange will deem compliance with the AIM Rules should an AIM company, that prepares their accounts in accordance with EU adopted IFRS, take advantage of the IFRS 16 Amendment as set out in the FRC Statement.
Coronavirus – IFRS 16 Amendment
Date: 19 August 2020
This Inside AIM sets out temporary changes relating to an AIM company’s obligation to notify half-yearly reports in accordance with the AIM Rules for Companies (“AIM Rules”).
Inside AIM dated 26 March 2020 set out our intention to keep under review the requirements for reporting of half-yearly reports pursuant to AIM Rule 18. Currently under the AIM Rules, an AIM company must notify its half-yearly report without delay and in any event within three months from the end of the period to which it relates.
From today, AIM Regulation will permit AIM companies that need extra time to prepare their half-yearly report an additional one month in which to notify them. This extension is temporary whilst the UK faces the disruption resulting from the coronavirus pandemic. We will keep these temporary measures under review and when the disruption to AIM companies eases, we will announce an orderly transition to standard reporting periods under AIM Rules 18 and 191.
An AIM Company wishing to utilise the additional one month period must notify via an RIS its intention to do so prior to the AIM company’s reporting deadline under AIM Rule 18 and the Company’s nominated adviser must separately inform AIM Regulation.
An AIM company should continue to consider its AIM Rules disclosure obligations in conjunction with the advice and guidance of its nominated adviser.
Inside AIM - COVID19 Half Yearly Reports
Date: 09 June 2020
1 The accounting period to which an extension for annual audited accounts may be sought pursuant to Inside AIM dated 26 March 2020 is superseded by this Inside AIM and such extensions will be available until further notice of an orderly transition back to standard reporting periods.
This Inside AIM sets out temporary changes relating to an AIM company’s obligation to publish annual audited accounts in accordance with the AIM Rules for Companies (“AIM Rules”).
The unprecedented events of recent weeks mean that there may be circumstances where an AIM company is unable to publish its annual audited accounts under normal legal and regulatory reporting deadlines.
Currently under the AIM Rules, an AIM company has six months after the end of its financial year to publish its annual audited accounts. This reporting requirement is consistent with the legal filing deadline for UK incorporated public companies under the Companies Act 2006.
We note the joint initiative of the Department of Business, Energy & Industrial Strategy and Companies House, to allow UK companies to apply to Companies House for a three month extension of the legal filing deadline [1].
Noting the above and to assist AIM companies in the preparation of their annual accounts in the current difficult circumstances, from today an AIM company will also be able to apply to AIM Regulation for a three month extension to the reporting deadline for the publication of its annual audited accounts pursuant to AIM Rule 19. This extension will be available for AIM companies with financial year ends between 30 September 2019 to 30 June 2020.
The request for extension must be made to AIM Regulation by the nominated adviser, prior to the AIM company’s current AIM Rules reporting deadline.
London Stock Exchange will keep under review the operation of the AIM Rules and in particular, the requirements for reporting of half yearly reports under AIM Rule 18.
Date: 26 March 2020
[1] Companies to receive 3-month extension period to file accounts during COVID-19
This Inside AIM sets out temporary measures that will be implemented by AIM Regulation to support AIM companies and nominated advisers as they seek to navigate some of the challenges arising from the unprecedented Coronavirus (COVID-19) pandemic.
Until further notice, AIM Regulation will be applying discretion to the application of certain of the AIM Rules for Companies and the AIM Rules for Nominated Advisers (“AIM Rules”), as set out below. We will continue to keep the situation under review, in particular the potential impact on financial reporting and will provide further guidance as necessary.
Temporary suspension of trading
Timely and accurate disclosure is a key requirement under the AIM Rules and all AIM companies should continue to meet their disclosure obligations without delay. It is therefore important that nominated advisers have a sound understanding of how their AIM companies are planning and responding to the events as they unfold, so that they are able to make disclosures in accordance with their AIM Rules obligations.
However, we recognise that an AIM company may face material new developments as a consequence of the restrictions and challenges being caused by Coronavirus (COVID-19). Accordingly, where an AIM company requires more time to make a fully compliant notification, than would be the case in ordinary circumstances, the nominated adviser should approach AIM Regulation to discuss whether a temporary suspension is required. Given the importance of disclosure, such a request will need to fully explain why the suspension is appropriate in the circumstances and any decision to suspend is at the discretion of AIM Regulation. If granted, such a temporary suspension will be for a limited period to enable the AIM company to make a fully compliant notification.
Suspended AIM companies
Currently where an AIM company has been suspended for more than six months, pursuant to AIM Rule 41 the company’s securities will be cancelled. We appreciate that, given the logistical challenges during this period, further time might be required to resolve the reason for suspension. Accordingly, we will be using discretion to extend the period to 12 months for any AIM company that has been suspended between 30 September 2019 and 1 July 2020.
Engagement responsibilities for a nominated adviser
When taking on a new client, as part of its due diligence, a nominated adviser is generally required to undertake a site visit to the AIM company’s material place of operations and meet the directors and key managers. Where travel restrictions and social distancing measures make it difficult to meet this obligation, provided that a nominated adviser uses alternative measures that are reasonably available (such as virtual meetings), we will temporarily suspend the requirement for a physical site visit. Once any applicable restrictions have been lifted, nominated advisers will be expected to undertake the site visit in order to fulfil its obligations under the AIM Rules.
We also recognise that in the current circumstances for the purposes of providing directors’ AIM Rules education, nominated advisers are likely to be undertaking telephone or virtual meetings with directors instead of physical meetings.
Coronavirus temporary measures
Date: 20 March 2020
We work closely with nominated advisers to ensure that they can maintain up to date and relevant AIM knowledge within their corporate finance functions to enable them to carry out the obligations they owe to London Stock Exchange under the AIM Rules for Nominated Advisers (“Nomad Rules”).
In this Inside AIM, we set out answers to some of the frequently asked questions in respect of staffing, particularly taking into account wider market conditions and trends.
Relevant Transactions
Market conditions can have an impact on the number of Relevant Transactions undertaken, as defined in Nomad Rule 5. Rule 5 provides discretion for us to consider equivalent work undertaken in respect of IPOs or other major public transactions where the work performed by the nominated adviser is similar to that of an AIM admission. When considering alternative transactions, we look for evidence that firms have undertaken work equivalent to the Admission Responsibilities set out in Schedule Three of the Nomad Rules and that the firm has retained overall management and responsibility for the transaction and transaction documentation. Below are examples of transactions we may consider accepting [1]:
We would also highlight that, as set out in Nomad Rule 5 and Inside AIM (Issue 1), both an applicant QE and an existing QE may cite the same Relevant Transaction if they have each been involved to an appropriate extent.
QE Applications
We have regular conversations with nominated advisers about their current and future resourcing plans and we work with, and support, nominated advisers as they develop their wider corporate finance staffing. One question we receive regularly is whether a QE in an existing firm will automatically transfer as a QE if they change firm or join a firm which is considering applying to become a nominated adviser.
QE status is considered in the context of the firm and is not an individual qualification | The wider staffing of the nominated adviser function beyond the minimum number of QEs is an important consideration for us (at both a junior and senior level). Accordingly, QE applications are considered in the context of the firm’s overall staffing, management controls, senior management supervision (of the nominated adviser team), junior support and compliance function. Underpinning this is the principle that QE status is not an individual qualification, but a designation granted to the firm denoting those individuals within the firm who are authorised by the Exchange to lead AIM Rules advice for that nominated adviser. Accordingly, QE status is not automatically transferable. |
A number of factors will be taken into account when considering QE applications | We will consider applications for QEs where a firm supports that individual to act as a QE on its behalf. Where an applicant is not able to demonstrate that all the required Relevant Transactions have been completed we may use the provisions of Nomad Rule 27 such as the requirement for ongoing supervision, as a condition of approval. In such circumstances we will look at a range of factors. For example, we will seek evidence that the applicant has a sound understanding of the UK corporate finance market and AIM in particular. We will also consider the support the applicant will receive and will take into account the wider staffing and controls within the firm. |
Maintenance of standards is our key objective | The criteria for QE approval are designed to ensure that a nominated adviser firm is in a position to meet its obligations owed to London Stock Exchange and thus to maintain standards across the market. We expect nominated adviser firms to bear this in mind when supporting a QE application and we will also take this into account in our considerations. |
Ensuring coverage for nominated adviser obligations
We are sometimes asked by nominated advisers about team working arrangements.
Individual working arrangements will be considered | Nomad Rule 4 refers to a ‘full-time employee’. The intention underlying the reference to ‘full-time’ is to ensure that QEs give full attention to the role and thereby to address the circumstances of individuals who undertake other professional services or employment outside of the business of the firm, such as NED roles. The designation of QE is for the benefit of the firm so that it can demonstrate that its AIM company clients have real-time access to appropriately experienced staff to lead regulatory support and advice. Therefore, a firm may consider individual working arrangements such as part-time or other forms of flexible working. |
Nominated advisers to ensure alternative arrangements do not impact performance of their obligations | Nominated adviser firms need to demonstrate that satisfactory arrangements are in place such that the role of a nominated adviser can be fully discharged. For example, this will mean that AIM company clients have ongoing access to QEs that have full knowledge of the company and its developments to be able to advise and guide it on its AIM Rules obligations in a real-time market environment. If part-time or flexible working arrangements are agreed, then this should be arranged in a way that supports the performance of such obligations. For example, by ensuring that clients have access to more than one QE with the requisite knowledge of its business. |
Compliance
An important element of the wider staffing of a nominated adviser firm is the compliance function. In addition to ensuring it has sufficient QEs, we encourage firms to consider what a “good” compliance function looks like, having regard to its specific structure and services. In our experience, the success of a compliance function is dependent on an engaged senior management team. When considering its compliance needs, amongst other things, a firm should consider a compliance function that:
Maintenance of knowledge and experience
Nominated advisers ask us about the benefits of commissioning an external review or training in respect of their obligations to London Stock Exchange and their understanding of the AIM Rules. Whilst we appreciate that firms might consider that taking external advice could evidence a commitment to their compliance with the Nomad Rules, we question the benefits of this approach noting that the role of a nominated adviser is different to that of other professional services firms. We think it is more meaningful for a nominated adviser to engage the experience and expertise within its team when conducting a review.
We generally find that the nominated adviser firms that share knowledge internally, have experienced staff beyond individual QEs, focus on individual and collective performance and supervision, and have good levels of management engagement along with an embedded compliance culture, are better placed to meet their nominated adviser obligations. We are always very happy to provide support and to provide firms with our experience gained from engagement across the market when they are considering or designing an internal review.
Staffing of Nominated Advisers
Date: 28 May 2019
[1] Such discretion is unlikely to be applied in relation to an entity seeking approval as a nominated adviser pursuant to Nomad Rule 2.
Companies whose shares have for the last 18 months been traded on certain markets may be eligible to use an AIM Designated Market route to admission. This route to market, streamlines the AIM admission process by dispensing with the requirement of producing an AIM admission document.
Today we have issued an updated AIM Designated Market Route publication. The new publication updates the list of AIM Designated Markets by introducing a new category extending to EU Regulated Markets and SME Growth Markets. The addition of the new category reflects harmonisation of investor protections and regulations in relation to securities admitted to trading on UK and European trading venues.
Potential applicants exploring this route to AIM should discuss details with a nominated adviser.
Date: 28 May 2019
From 28 September 2018, AIM companies will be required to disclose details of the recognised corporate governance code they have decided to apply. Companies will have to explain how they comply with their chosen corporate governance code and, where they depart from the code, provide an explanation of the reasons for doing so.
Good corporate governance is supported by a detailed explanation of a company’s practices against the principles of a chosen code, in a manner that enables shareholders to evaluate how the principles have been applied, rather than simply identifying areas of non compliance. This principles-based approach to corporate governance is consistent with our overall approach to AIM. Accordingly an AIM company should exercise due care to ensure that the information in their corporate governance statement is informative and not misleading.
We have engaged with nominated advisers in preparation for the changes. The feedback has indicated that AIM companies are progressing well. The guidance below addresses some of the common questions received from nominated advisers as part of our engagement.
Timing of disclosure
On 8 March 2018 the Exchange confirmed that it would introduce a requirement for AIM companies to disclose on their website how they ‘comply or explain’ against a recognised corporate governance code. To provide AIM companies and nominated advisers with adequate time to prepare for the change, we confirmed that AIM companies have until 28 September 2018 to implement the new corporate governance disclosure requirements.
After 28 September 2018, an AIM company will have to review its corporate governance disclosures annually. We expect that in most cases this review will take place at the same time as the company prepares its annual report and accounts. An AIM company’s website should include the date when it last reviewed its compliance with its chosen code and, in conjunction with this review, update its AIM Rule 26 disclosures to remain accurate.
Where to make your corporate governance disclosure
AIM Rule 26 requires an AIM company’s corporate governance statement to be published on its website. The disclosure on its website should be clearly presented and easily accessible from the ‘AIM Rule 26’ landing page on its website. It is acceptable for the statement to incorporate by reference (for example disclosures that are provided in a clearly delineated corporate governance section of the annual report) provided that the material is freely available and the statement clearly indicates where interested parties can read or obtain a copy of that material (for example, the relevant pages or section of the annual report or the URL for the relevant web page).
If an AIM company has not yet made disclosure against a recognised code in its annual report, the corporate governance statement must be disclosed on its website by 28 September 2018, in accordance with AIM Rule 26.
Recognised code
The Exchange has not prescribed a list of recognised codes as it remains preferable for AIM companies to have a range of options to suit their specific stage of development, sector and size.
However, we have referred to established benchmarks for AIM company codes such as the QCA Corporate Governance Code and the UK Corporate Governance Code. Further, for AIM companies that have a dual listing in their home state, we have confirmed it is acceptable to report using an appropriate standard in their home jurisdiction. For example, an AIM company which is incorporated in Australia and listed on both ASX and AIM is able to rely on its disclosures pursuant to the ASX Listing Rules (i.e. recommendations set by the ASX Corporate Governance Council) so long as this disclosure is available on its website and reviewed annually, in accordance with AIM Rule 26
It is important to note that the requirements of the code applied by AIM companies are not set by the Exchange, but by third parties. Accordingly, AIM companies should ensure they keep informed of any changes to the recognised code they apply.
Good corporate governance and investor engagement
Good corporate governance is not simply about codes or rules; it involves strong leadership, a positive culture, robust systems and risk management. These all encourage and reinforce behaviours that ensure company representatives act to protect the interests of the company and its shareholders. In order to facilitate discussions with investors, disclosure is essential. Accordingly, the new corporate governance requirements are intended to provide information to investors to enhance the engagement between investors and the boards of AIM companies. However, disclosure alone does not constitute good corporate governance.
It is for investors to determine whether the corporate governance policies, practices and any reasons stated for non compliance with the adopted code, are appropriate for the AIM company, taking into account factors such as its stage of development, sector and size.
Preparation for corporate governance changes
Date: 26 July 2018
Social media and other forms of electronic communication are powerful tools which can be of significant value to AIM companies when communicating with a broad range of investors and stakeholders. Such communications may include ‘twitter’, non-regulatory news feeds, an AIM company’s website etc. Whatever the form of public communication, these are subject to the same rules regarding disclosure of regulatory information.
With the increased use of such forms of communication, AIM companies should consider with their nominated adviser how to manage social media in the context of their obligations under the AIM Rules for Companies (“the AIM Rules”).
Requirement for notification to a RIS “no later than it is published elsewhere”
The fact that information released through other outlets may be, or may eventually become publically available, is not a substitute for making a notification under the AIM Rules no later than it is disclosed elsewhere. This includes releasing the information to the media even on an embargoed basis. So, disclosure by social media alone will not meet an AIM company’s disclosure requirements and an AIM company must continue to use traditional means of regulatory dissemination which take precedence.
AIM Rules 10 and 11 are important in ensuring there is equal, fair and timely disclosure of regulatory information to the market and that integrity in the market is maintained. The consequence of not doing so, from an AIM Rules perspective, may be the suspension of an AIM company’s securities from trading pending a compliant notification where there has been unusual share price movement because of an inequality of information in the market. We may also require an AIM company to issue a clarification notification where comments made via social media by directors, or persons on behalf of an AIM company are inconsistent with notifications made via a RIS.
Further, if London Stock Exchange considers that an AIM company has breached AIM Rules 10 and/or 11, it will investigate and take such disciplinary action as it considers appropriate.
An AIM company should, of course, have regard to MAR which is within the remit of the FCA and must be considered separately to its AIM Rules obligations. Where premature or selective disclosure has been made, or where communications are designed to cause share price volatility (e.g. through a tip or leak of confidential information about the AIM company) this may also give rise to issues beyond the AIM Rules, and are within the remit of the FCA’s powers relating to market abuse.
Systems, procedures and controls
AIM companies that make use of social media should consider with their nominated adviser how the dissemination of information is supervised and monitored to ensure compliance with its disclosure obligations under the AIM Rules.
The systems, procedures and controls an AIM company puts in place (as required by AIM Rule 31) should take into account the use of social media and other forms of electronic communication used by the company in order to manage its’ disclosure obligations under the AIM Rules. Communication policies should be considered in a meaningful way, taking into account the needs of the particular company and in this context, some obvious things to consider, by way of example only, include:
As a final point, consideration should be given by an AIM company and its nominated adviser (as part of its OR3 obligations) as to how to be reasonably be kept informed about social media posts, for example relevant internet discussion forums. This is important in the context of enabling the nominated adviser to be alerted to potential disclosure issues for its AIM companies such as whether a false market might be developing in an AIM company’s securities, as well as indicating a leak of confidential information.
An AIM company through its nominated adviser should continue to make London Stock Exchange aware of significant rumours or problems relating to internet discussions, which may impact on the orderly market in the securities. Whether the AIM company is required to make a notification will depend on the particular circumstances.
Date: 12 December 2016
AIM Notice 45 referred to FCA’s supervisory approach in respect of closed periods and preliminary results under the Market Abuse Regulation (“MAR”). The Notice welcomed FCA’s approach and confirmed that we would review the AIM Rules for Companies (“the AIM Rules”) once further clarification was provided by ESMA. In this regard we note that on 13 July 2016 ESMA updated its 'Questions and Answers' on MAR (“Q&A”).
ESMA’s Q&A mirrors the approach of the FCA set out in their statement published on 25 May 2016. We refer AIM companies and their advisers to this new ESMA Q&A for further information.
Given this clarification by ESMA, we do not consider it necessary to amend the AIM Rules.
We continue to support the use of Listing Rule 9.7A.1 by AIM companies as a benchmark in relation to the preparation of a preliminary results announcement.
Frequently asked questions for AIM companies and their nominated advisers in respect of MAR and the AIM Rules are now available at this link.
Market Abuse Regulation (MAR) - Closed periods and preliminary results
Date: 2 August 2016
On 3 July 2016, the Market Abuse Regulation (MAR) will come into force. MAR is an EU regulation which is directly applicable across all member states. MAR includes disclosure obligations for issuers admitted to trading on regulated markets or MTFs, and accordingly, will apply to AIM.
As set out in in AIM Notice 44, London Stock Exchange is consulting on changes to the AIM Rules for Companies (“the AIM Rules”) as a consequence of the introduction of MAR.
This Inside AIM sets out information to support nominated advisers as they work with their clients to prepare them for the introduction of MAR and consequent changes to the AIM Rules. The contents of this Inside AIM are based on the assumption that the proposals set out in AIM Notice 44 are implemented.
We will continue to keep the operation of our rules under review.
Overview of MAR obligations
The key disclosure obligations in MAR relate to the disclosure of inside information and disclosure of deals by persons discharging managerial responsibilities (“PDMR”) and closely associated persons. MAR will also introduce mandatory close period rules.
AIM Rule 11
The purpose of AIM Rule 11 is to maintain a fair and orderly market in securities and to ensure that all users of the market have simultaneous access to the same information in order to make investment decisions. The disclosure obligation in respect of inside information under Article 17 of MAR protects investors from market abuse (see recital 49 of MAR).
Whilst there is clearly overlap in respect of both sets of obligations, they should be considered separately. In particular, we note that “inside information” has a specific and technical definition (given its context) whereas consideration of AIM Rule 11 by an AIM company (with the guidance of its nomad) is a principles based consideration in the context of the maintenance of a fair and orderly market. Therefore, the separate disclosure tests and guidance to AIM Rule 11 must be complied with.
Importantly, compliance with MAR does not mean that an AIM company will have satisfied its obligations under the AIM Rules, just as compliance with the AIM Rules does not mean that an AIM company will have satisfied its obligations under MAR. An AIM company must comply with the AIM Rules and MAR at all times.
For example, the guidance to AIM Rule 11 which sets an expectation that an AIM company should keep impending developments confidential under the AIM Rules would not restrict an AIM company from making such a disclosure if required under Article 17 of MAR. Equally, the ability to delay the publication of inside information under MAR would not override the disclosure obligation contained in the AIM Rules. In this regard an AIM company must consider whether it is able to delay the information pursuant to the guidance to AIM Rule 11.
An AIM company should continue to consider its AIM Rules disclosure obligations in conjunction with the advice and guidance of its nominated adviser pursuant to AIM Rule 31. It will not be a defence to a breach of the AIM Rules that the AIM company had received legal advice that it was MAR compliant. In this regard, we do not expect a different approach by AIM companies and nominated advisers to compliance with AIM Rule 11 post MAR. The AIM Rules are principles based and accordingly, as is the case currently, the consideration of AIM Rule 11 disclosure obligations should not be overly narrow or technical. We consider this approach to compliance with AIM Rules 11 and 31 is fundamental to ensuring market integrity. Failure by an AIM company to comply with AIM Rule 11 or to seek the advice and guidance of its nominated adviser (and take that guidance into account) pursuant to AIM Rule 31, will be regarded as a serious breach of the AIM Rules and may result in the London Stock Exchange taking disciplinary action in addition to our powers to suspend or cancel an admission.
Collaboration with FCA
FCA is the competent authority for MAR in the UK and its powers are contained in Article 23. Therefore, whilst FCA will have powers to intervene as competent authority and will be responsible for the investigation and enforcement of breaches of MAR, we intend to work closely with the FCA to co-ordinate our approach to obtaining any necessary information from AIM companies whilst minimising duplication of activities.
It is important for the effective overall operation of the market that real time monitoring and management of the market continues to be undertaken by London Stock Exchange, as market operator. In practice, where there is a query as to whether an AIM company should make a disclosure, we will continue to liaise with the AIM company’s nominated adviser regarding its AIM Rules obligations and will provide the FCA with information about these discussions, where relevant to MAR. It is open to the FCA to consider an AIM company’s compliance with MAR at any time.
For the avoidance of doubt, we will not be able to opine on MAR obligations/compliance. Any guidance provided by AIM Regulation in respect of disclosure will only be in relation to an AIM company’s obligations under the AIM Rules.
PDMR dealings
Article 19 of MAR (PDMR transactions) contains notification requirements which will apply to issuers, PDMRs and persons closely associated with them. Article 19 will also include mandatory close period rules. Given the scope of MAR, duplicate obligations will be removed from the AIM Rules. However, we consider it is important for the integrity of the market that AIM companies have in place systems and controls to manage these obligations. We therefore have proposed to amend AIM Rule 21 to require all AIM companies to have a dealing policy and to require nominated advisers to consider this as part of their responsibilities.
We do not intend to prescribe the detailed content of the dealing policy but we have in AIM Notice 44 set out the minimum provisions that we would expect to be included in the policy. We expect AIM companies and nominated advisers to consider the design and implementation of the policy in a meaningful way, to ensure it is capable of working in practice, taking into account the nominated adviser’s knowledge of the company and its management. This obligation will be separate to an AIM company’s compliance with Article 19. Accordingly, an AIM company’s compliance with MAR will not mean it will have automatically satisfied its obligations under AIM Rule 21.
Insider lists
Following implementation of MAR, all AIM companies will be required to maintain a list of all those persons working for them that have access to inside information. The FCA, as competent authority for MAR in the UK will be responsible for enforcing compliance with this provision. Accordingly, AIM companies will need to implement systems and controls to comply with these obligations.
Although MAR includes provisions for issuers on SME Growth Markets to draw up a list only when requested by the regulator, the SME Growth Market regime will not into come into force until MiFID II is implemented in January 2018. AIM is currently not a SME Growth Market, so AIM companies will therefore be required to comply with Article 18.
Preparation for market abuse regulation
Date of publication: 29 April 2016
On 3 July 2016, the Market Abuse Regulation ("MAR") will come into force. MAR is an EU Regulation which has direct effect across all EEA member states and will supersede the existing Market Abuse Directive.
MAR disclosure obligations will apply to financial instruments admitted to all multilateral trading facilities, as well as regulated markets. Accordingly, these obligations will apply to all issuers admitted to European growth markets including AIM.
The key disclosure obligations in MAR relate to the disclosure of inside information and disclosure of deals by persons discharging managerial responsibilities and closely associated persons. MAR will also introduce mandatory close period rules.
This article sets out our preliminary thoughts on how we expect MAR obligations to sit alongside the disclosure obligations in the AIM Rules for Companies ("AIM Rules").
AIM Disclosure Rules
The disclosure obligations under MAR will be within the remit of Financial Conduct Authority ("FCA") as the UK competent authority and we have been working closely with the FCA to co-ordinate our approach to the implementation of MAR for AIM companies.
We have given consideration to whether it remains appropriate to retain the disclosure provisions contained within AIM Rule 11 following the implementation of MAR. On balance, we consider that retaining a disclosure rule in the AIM Rules is important to the integrity of AIM and the maintenance of an orderly market. We also consider that the disclosure requirement in AIM Rule 11 (as currently drafted or with minor amendments) will continue to reinforce our expectations of AIM companies to provide equality of information on a timely basis, allowing investors to make informed investment decisions.
Retaining AIM Rule 11, should not materially change a company’s approach to disclosure compared to existing market practice. Although we appreciate that retaining the AIM disclosure rules will mean that AIM companies will have obligations to both AIM Regulation and the FCA, we will work closely with FCA to minimise any duplication. For example, in respect of real time disclosure, it is currently envisaged that in the first instance AIM Regulation will continue to have discussions with nominated advisers and will co-ordinate with the FCA as necessary.
Whilst we consider that the above approach will mitigate the need for an AIM company to engage separately with two regulators in most situations, it should be noted that only the FCA, as the competent authority under MAR, will be able to opine on MAR compliance and will retain the right to engage directly with an AIM company if necessary.
The AIM Rules already sit alongside wider regulatory and legal obligations owed by an AIM company as described at AIM's Regulatory Landscape.
Although we have already sought views from various market participants, we will undertake a market consultation if changes to the AIM Rules are required. In the meantime, we would welcome further feedback from market participants which should be addressed to aimregulation@lseg.com.
Date of publication: 28 October 2015
Introduction
This Inside AIM article relates to AIM company disclosures arising from equity financing products that involve AIM securities and in which AIM companies or their directors may have an interest. By way of illustration only, these products include:
Given the importance of ensuring correct disclosures to the orderly operation of the market, it should be noted that London Stock Exchange has required correction of notifications that had incorrectly disclosed the terms of such equity financing arrangements.
Complexity and Non Standard Terms
Some of these equity financing products may, by their nature, be complex. AIM companies and their nominated advisers should carefully evaluate the structure of, and any non-standard terms contained within, such facilities when considering disclosure requirements to ensure that the information provided is sufficient to give a proper understanding to investors. This may involve providing more detail than would ordinarily be the case for more commonly used forms of financing and in all cases should properly reflect the substance of the transaction.
As an example, depending on the nature of the product, the AIM company and its nominated adviser should consider whether in respect of company equity financing facilities, the circumstances of a draw-down request (and the notice of such) gives rise to an AIM Rules disclosure obligation in its own right, pursuant to AIM Rules 10 and 11 and not just the actual draw down itself. Matters which may be relevant to such consideration could include:
Disclosure of Directors Share Dealings
In addition to equity financing arrangements available to AIM companies, products are available to directors of public companies to enable them to use their own holding in the AIM company as a means of personal financing by way of, for example, share sale and repurchase agreements.
In order to comply with the AIM Rules, it is important that AIM companies carefully evaluate the consequences of these agreements, most particularly in relation to the requirements on the AIM company to correctly and fully disclose directors’ dealings under the AIM Rules.
The definition of a “deal” under the AIM Rules is, of course, very broad and encompasses almost any action a director might take in relation to his interest in his holding of securities in that AIM company. Accordingly, the nature of any director’s dealings arrangements should be clearly and fully disclosed, most usually at the time that a transfer of an interest in the shares becomes binding (whether that transfer occurs now or in the future).
Further, care should be taken when using terminology to describe the nature of the arrangement to ensure appropriate and sufficient disclosure. For example, share sale and repurchase agreements are distinct from secured loans/share pledges in a number of key areas (in particular, in relation to the point at which an interest in shares is transferred). The transfer of voting rights is also an important consideration that may require disclosure.
After the initial disclosure of any equity financing arrangements, AIM companies should make appropriate updates, for example, where there are changes to director’s previously stated intentions or if a director does not meet a margin call that results in that director’s holding in the AIM company changing including, for example, losing rights under the relevant agreement.
Systems and Controls for Disclosure
In respect of directors’ personal deals, given that an AIM company is often not a party to these equity financing arrangements, an AIM company’s agreements with its directors should ensure that it can obtain from directors all information that the AIM company will need in order to comply with its director dealing notification requirements under AIM Rule 17 where a director enters into arrangements relating to his or her AIM company holding. This is an important element of the requirements of AIM Rule 31.
Consideration should also be given to who within the AIM company is best placed to be involved in the preparation of notifications to the market where key executive directors, or a number of directors, are involved in equity financing arrangements. London Stock Exchange would expect, as part of an AIM company’s AIM Rule 31 processes, that appropriate independence is exercised in the preparation of a notification.
AIM companies are advised to consult with their nominated adviser at the earliest opportunity about the proper disclosure of these types of arrangements. Nominated advisers should consult with AIM Regulation if they are in any doubt as to the disclosure requirements.
AIM Company Disclosures relating to Equity Financing Products
Date of publication: 24 September 2015
Due to certain restrictions under US securities laws, equity securities issued by US companies and other companies that do not qualify as "foreign private issuers" under US securities laws were historically not eligible for electronic settlement in the CREST system operated by Euroclear UK & Ireland ("EUI"). Such securities were generally settled in certificated form and flagged as Regulation S, Category 3 securities in the trading system ("Regulation S, Category 3 securities").
The introduction of the EU Regulation on Central Securities Depositories (Article 3(2)) requires transactions in transferable securities that take place on a trading venue (such as AIM) to be recorded in book entry form in a CSD (i.e. settled electronically). Accordingly, the Exchange has been working with EUI and other relevant parties for a resolution that will allow such securities to be able to be settled electronically.
The Exchange welcomed the publication by EUI on 11 May 2015 of its whitebook relating to its proposed "Euroclear UK & Ireland: Regulation S Category 3 Settlement Service". The service provides issuers of Regulation S, Category 3 securities with an electronic settlement service through CREST.
We expect all existing Regulation S, Category 3 securities to be eligible for electronic settlement by no later than 1 September 2015. We have updated the Rules of the London Stock Exchange for member firms (rule 1550) and accompanying guidance to the rule, which relates to all member firms trading Regulation S, Category 3 securities. For further details see Stock Exchange Notice N17/15 published on 7 August 2015.
New AIM applicants that propose to issue Regulation S, Category 3 securities are reminded to request a derogation from Rule 32 of the AIM Rules (transferability of shares) prior to admission and clearly disclose on the AIM Application form whether they are Regulation S, Category 3 securities, as they will be identified as such on the trading system with the letters "REG S". It should be noted that derogations from Rule 36 of the AIM Rules will no longer be available for such securities.
Further background can also be found in AIM Notice 41 published on 7 August 2015.
Regulation S Category 3 Securities
Date of publication: 7 August 2015
AIM is an international market for growth companies covering a broad range of sectors with a wide range of market capitalisations. Given this, the AIM Rules take a principles based approach to ensure that they are relevant to the needs of such companies.
A company’s free float is an important qualitative assessment, which can have a significant impact on the ability of the company to attract investors and the functioning of the secondary market. Whilst we do not prescribe levels of free float, the issue of free float is something that we consider an important factor in the work a nominated adviser undertakes when bringing an applicant to market. Sufficient free float is fundamental to the orderly trading and liquidity of the securities once admitted to AIM, which is inextricably linked to the company’s appropriateness to be admitted to AIM.
Nominated advisers will be aware that we often ask them to provide us with details about the factors they have considered in relation to free float when seeking to bring a company to AIM. As a consequence, this is an area where we thought it would be helpful to clarify some of the factors we often discuss with nominated advisers, including the following:
Consideration should be given to how the securities are likely to trade when admitted to AIM, following discussion with the company’s broker(s) and potential market makers. We would expect consideration to be given to the spread and nature of the shareholders comprising the free float;
Failure to raise initial target funds (which in itself might give rise to free float questions) may be indicative of more fundamental issues of appropriateness and is a matter that should be properly explored by the nominated adviser;
Limited free float should give rise to questions about the rationale for the applicant to seek admission to AIM;
Where there are concentrated shareholdings (e.g. connected due to family, business or other interests/ connections) free float issues should be considered in conjunction with issues of undue influence, control and ongoing corporate governance arrangements within the company.
Date of publication: 1 June 2015
Pursuant to AIM Rule 31, AIM companies are required to have in place sufficient systems, procedures and controls to enable them to comply with the AIM Rules. This is an area which the nominated adviser is also required to consider.
Such consideration involves, for example, the review of financial policies and procedures documentation prepared by the company (in conjunction with its reporting accountants). Nominated advisers should approach this consideration in a meaningful way, which would go beyond merely a review of the relevant documents to include an assessment of whether those policies are capable of working in practice, taking into account the nominated adviser’s knowledge of the company and its management.
The Exchange also notes that such systems, procedures and controls must be in place by the time of admission.
Systems, Procedures and Controls - Financial Policies and Procedures
Date of publication: 1 June 2015
Please find below inside AIM newsletters- issues 1 to 5
The technical guidance provided in Inside AIM should be regarded as illustrative only. It is intended to give an indication of how AIM Regulation expects certain aspects of the AIM Rules to be interpreted and is not definitive. AIM Regulation should be contacted by a company's nomad if clarification or a derogation from the rules is required.
As usual, AIM companies should continue to seek the guidance of their nomad when looking for assistance on the application of the AIM Rules.
Any amendments to existing AIM Rules will continue to be communicated via AIM Notices and will be subject to the usual public consultation process where appropriate. Amendments to our rules will not be introduced through Inside AIM.
Inside AIMs have not been updated following the UK's exit from the European Union, therefore in the context of historic references to EU regulation, users should refer to the relevant UK onshoring financial services legislation under the European Union (Withdrawal) Act (EUWA) 2018.
AIM Notices are issued periodically, and contain information on AIM regulatory and administrative matters. They also include details of any amendments to the existing rules, together with guidance on interpreting and applying them.
If you would like to receive our AIM Notices regularly by email, please send an email to aimnotices@lseg.com.
Please find below AIM notices from 2002 to 2009.
You can access more information on AIM advisers.
You can access reports related to AIM.
London Stock Exchange is a Recognised Investment Exchange (RIE) under the UK’s Financial Services and Markets Act (FSMA).
AIM is operated and regulated by the Exchange in this capacity under Part XVIII of FSMA 2000, and as such AIM is a ‘prescribed market’ under FSMA 2000 which brings it within the market abuse provisions.
London Stock Exchange operates AIM with an overarching objective of maintaining the integrity and reputation of its growth market. The market structure and rules are designed to be relevant to growth companies and their investors. The Exchange undertakes its regulation of AIM through its AIM Regulation and Market Supervision teams. AIM Regulation is responsible for the compliance by AIM companies and Nominated Advisers with the AIM Rules and the Market Supervision team monitors the trading in AIM securities by member firms which are subject to London Stock Exchange’s trading rules.
AIM companies and nominated advisers
The AIM Rules for Companies and AIM Rules for Nominated Advisers form the basis of London Stock Exchange’s regulation of AIM companies and the nominated advisers. The AIM Rules sit within a wider landscape of regulatory and legal duties which are broadly similar to those protections provided to Main Market companies and their investors. Accordingly, the Exchange’s remit in respect of companies admitted to AIM is limited to compliance with its rule books. Actions of companies and directors that relate to wider legal duties and obligations are within the remit of the relevant competent body or regulator. The AIM Regulation team at London Stock Exchange undertakes its regulatory role by reference to the AIM rule books:
The AIM rule books have been designed to ensure that the rules governing companies admitted to AIM are relevant to meet the needs of growing companies and their investors. They sit alongside primary legislation which is the remit of other regulators and law enforcement agencies that also provide protections to investors in respect of AIM in the same way as they do for the Main Market.
London Stock Exchange undertakes a lead role in the regulation of AIM and works closely with other regulators and law enforcement bodies to ensure that the investigation and enforcement of matters relating to AIM companies, their directors or potentially abusive trading in AIM securities are undertaken by the authority that has the most appropriate remit and investigation and enforcement powers.
The activities of the AIM Regulation team within the Exchange include: policy matters and changes to the AIM rule books; authorising and approving firms to act as nominated advisers; providing advice and guidance to nominated advisers on the interpretation of the AIM Rules; and providing oversight of the performance by the nominated advisers of their obligations owed to the Exchange pursuant to the AIM rules.
Furthermore, the AIM Regulation team undertakes investigations and considers disciplinary action in respect of potential breaches of the AIM rule books by AIM companies and/or nominated advisers. AIM Regulation has a variety of private and public sanctions it can utilise in respect of the enforcement of its rules. All public censures are published and London Stock Exchange will also publish private censures (anonymising the relevant company/nominated adviser) for the purpose of educating the market in circumstances where the nature of the breach is not sufficient to warrant a public censure or is unlikely to reoccur. This range of sanctions enables London Stock Exchange to apply the most appropriate sanction taking into account all the circumstances and ensuring that it achieves its objectives of providing education to the market; ensuring change in future behaviour; and deterring future breaches.
Trading of AIM securities on London Stock Exchange
The Market Supervision team at London Stock Exchange monitors the trading in AIM securities that is undertaken on the Exchange by member firms to ensure trading is orderly, efficient and in compliance with the London Stock Exchange’s trading rules. It also refers to the FCA potential cases of market abuse that it may identify.
London Stock Exchange’s AIM Regulation and Market Supervision teams work closely with and liaise on relevant market issues including ensuring that real time issues of disclosure are addressed by AIM companies on a timely basis and in accordance with the AIM Rules.
The suspension of AIM securities from trading is part of the Exchange’s real-time operation of AIM to maintain an orderly market, including where a company has not been able to make appropriate disclosure promptly. If a company is not able to comply with the AIM rules for a prolonged period its admission may be cancelled.
Nominated advisers
A key feature of AIM is the nominated adviser role. Nominated advisers are firms that provide corporate finance advice with particular expertise on AIM and are approved by the Exchange to act for companies that have, or wish to have, their securities admitted to trading on AIM. They will advise and guide the company on its ongoing obligations under the Exchange’s AIM rule books. A company admitted to AIM is required to have a nominated adviser at all times whilst it has securities admitted to trading.
It is the nominated adviser who will assess whether a company is appropriate for AIM, having considered all relevant matters set out in the AIM Rules. The nominated adviser will also advise on the compliance of the company’s Admission Document with the relevant rules. The nominated adviser makes a declaration to the Exchange in relation to this. The nominated adviser is also required to understand the business of the company so that it is well placed to provide ongoing support to the company in respect of its compliance with the AIM Rules, for example, in relation to matters such as ongoing disclosure. Whilst this support is important for AIM companies given their size and nature, it should be noted that the primary obligation for compliance with the AIM Rules for Companies remains at all times with the AIM company.
The Nominated Adviser Rules set out obligations owed by nominated advisers solely to the Exchange. These rules do not deal with the services that a nominated adviser may provide directly to its clients, for example, through its contract with an AIM company. Any such services between the nominated adviser and the AIM company will normally be set out in a private agreement. It is likely that a nominated adviser firm might undertake other roles for a client company, e.g. sales or broking. Whilst these are not regulated by the Exchange, the AIM Rules for Nominated Advisers contain provisions governing independence and conflicts of interest.
Lawyers
Lawyers will be involved in the admission of a company to AIM, including performing legal due diligence on the business and advising and guiding both the company and the nominated adviser on the legal aspects of the admission process. As with any company or business, AIM companies may choose to engage lawyers to advise them on an on-going basis in relation to various discrete matters including commercial contracts, acquisitions, corporate activity and compliance with legislation. However, an AIM company’s nominated adviser remains the company’s principal adviser in relation to its compliance with the AIM Rules.
Accountants and auditors
A firm of accountants, as reporting accountants, will be required to perform financial due diligence on a company as part of its proposed admission to AIM.
Furthermore, a company will have filing obligations under its Companies Act obligations as well as under the AIM Rules which require the company to notify a half-yearly report within three months of the period end and to publish an annual report and audited accounts for each financial year within 6 months of the year end. Therefore, every company must engage an auditor to audit its accounts. The UK’s Financial Reporting Council provides independent oversight over public company accounts and the regulation of auditors. In addition, an AIM company may also engage accountants to assist it in relation to ongoing financial reporting or in relation to discrete matters, such as tax matters, on an ad-hoc or regular basis.
Registrars
All companies will need to maintain a share register and this function is often outsourced by publicly traded companies, including AIM companies, to a professional registrar. The primary role of the registrar is to maintain the company’s share register and ensure that it is up to date. The registrar may also provide additional services including company secretarial services and/or facilitate formal regulatory communications with shareholders (e.g. notices of general meetings etc.).
As the leading financial services regulator in the UK, the FCA has three objectives, set out in FSMA (as amended by the Financial Services Act 2012): Protect consumers, to secure an appropriate degree of protection for consumers; Protect financial markets, to protect and enhance the integrity of the UK financial system; and to Promote competition, to promote effective competition in the interests of consumers. The FCA regulates London Stock Exchange, as a Recognised Investment Exchange. From an AIM company perspective, it has powers to investigate disclosures made by an AIM company where they may be false or misleading statements and which (intentionally or recklessly) induce investors to trade or refrain from trading in the company's securities. The FCA is also the competent authority in respect of the compliance with the relevant aspects of the FCA’s Disclosure and Transparency Rules which apply to UK companies on AIM (i.e. vote holder and issuer notification rules under DTR 5).
From a secondary market perspective (i.e. in respect of the trading of shares in the secondary market), the FCA has both civil and criminal powers available to it to identify and prevent market abuse and will also work with other law enforcement agencies in combatting this. Furthermore, given the FCA’s responsibility for the conduct of retail and wholesale financial services firms in relation to consumers, the manner in which these firms are expected to conduct business when communicating with clients is primarily set out in the FCA’s Conduct of Business sourcebook.
For more information, refer to: http://www.fca.org.uk/about/what
The Panel is an independent body in the UK whose main functions are to issue and administer the City Code on Takeovers and Mergers (the "Code") and to supervise and regulate takeovers and other matters to which the Code applies. Its central objective is to ensure fair treatment for all shareholders in takeover bids.
The Code applies to all companies admitted to trading on AIM which are incorporated in the UK, the Channel Islands and the Isle of Man.
For more information, refer to: http://www.thetakeoverpanel.org.uk/
The Serious Fraud Office is a government department and is part of the UK criminal justice system. Its aim is to investigate and prosecute serious and complex fraud and so deter fraud and maintain confidence in the probity of business and financial services in the United Kingdom. The SFO also has power to take criminal action in issues of insider dealing. The SFO will investigate "boiler room" fraud depending on the seriousness and complexity of the circumstances. The FCA, City of London Police and Action Fraud (the UK National Fraud & Cyber Crime unit) may also have an interest in and take action where such fraud is suspected.
For more information, refer to: http://www.sfo.gov.uk/
A company’s shareholders play a vital role in holding a company and its directors to account by virtue of rights enshrined in company law including the ability to vote on resolutions put to shareholders at general meetings which will include the election and removal of directors, pre-emption rights and the right to requisition a general meeting (subject to a sufficient proportion of shareholders supporting such an action).
Shareholders also have their own obligations under the Disclosure and Transparency Rules to report their shareholding to the company to enable the company to meet its own notification obligations in respect of its significant shareholders. Oversight of compliance of these obligations of shareholder disclosure is the remit of the FCA.
Certain legal remedies against a company may also be available to shareholders under company law in circumstances where the directors have acted outside of their powers.
An AIM company will be subject to a range of regulatory and legal obligations which it must comply with. Its AIM Rules obligations are just one aspect of this. The primary obligations owed by a company are set out under company law. A company will have in place articles of association which set out the constitution of the company, including the core duties and obligations of its shareholders and directors.
In respect of a company’s obligations under the AIM Rules, the responsibility for compliance rests primarily with the company itself and it must have in place appropriate procedures, resources and controls to ensure compliance, seeking advice from its nominated adviser whenever appropriate and taking that advice into account in meeting its obligations.
AIM Regulation provides an e-mail enquiry and telephone service for Nomads, as they are the primary regulators of AIM companies. In exceptional circumstances, AIM Regulation is able to deal with queries from an AIM company’s other advisers, such as lawyers and accountants, or from the company itself.
1. The AIM Rules for Nominated Advisers state that AIM Regulation will not provide guidance on a ‘no-names’ basis in relation to detailed or specific regulatory matters. The relevant company’s name and the enquirer’s details should be disclosed to AIM Regulation so it can provide appropriate advice. All information received is kept confidential, in accordance with the AIM rules. If AIM Regulation does provide any guidance on a ‘no-names’ basis, it is provided for general, high-level purposes only and it is non-binding upon the Exchange and should not be relied upon.
2. Before contacting AIM Regulation, please ensure you have first checked all appropriate resources. Contacting AIM Regulation should not be treated as a substitute for reviewing these in the first instance.
3. Complex or specific queries, class test queries or requests for rule derogations must be sent by email by a company's Nomad.
4. When contacting AIM Regulation, you must provide it with all the material information necessary for it to advise on the query. If AIM Regulation provides advice or a derogation and the information on which this was based subsequently changes, you should approach AIM Regulation again as soon as possible.
5. AIM Regulation strives to respond to all queries as quickly as possible. However, complex or policy-related queries may require three business days or possibly longer if the team needs to access further information. This timescale should be factored into any transaction timetable. In any event, AIM Regulation should always be contacted at the earliest opportunity.
6. An adviser should not assume that a derogation from the AIM Rules has been provided unless a member of the AIM Regulation team has confirmed this specifically in an email to the company’s Nomad.
7. Please note that all telephone calls to and from AIM Regulation are recorded to enable London Stock Exchange to carry out its regulatory responsibilities. Please see the AIM Regulation privacy statement below for further details.
You can contact AIM Regulation preferably by email on aimregulation@lseg.com or alternatively on +44 (0) 20 7797 4154.
If your query relates to a secondary markets matter only, please contact the Exchange’s Market Supervision team on +44 (0) 20 7797 3666 (STX 33666).
If you have a complaint relating to an AIM company or a Nomad’s compliance with the AIM Rules, please e-mail aiminvestigations@lseg.com. If you have a complaint about the Exchange, please click here for more details.
Privacy Statement
Any personal information which you provide on these forms will be used by London Stock Exchange plc for the purposes of regulating AIM. If you are providing any personal information on behalf of another individual, you confirm by submitting such form that you have provided all necessary notices and, where required, have obtained that individual's consent to do so. In some cases, it may be necessary to carry out background checks on individuals using the information contained in these forms which, where permitted by law, may include criminal record disclosures. To carry out these checks, we may need to disclose personal information to, and collect information from, third party partners, with whom we have entered into binding arrangements to regulate the sharing of data, including its security, where appropriate. We carry out these checks in order to enforce the AIM Rules, and to ensure AIM’s reputation and integrity. We will only disclose information which may identify you as an individual where we believe it is necessary or advisable to do so in relation to these purposes. You have certain rights in respect of your personal information, including to access it, or to amend it where it is inaccurate. To investigate exercising any of these rights, or to find out more about our data protection and privacy practices, please refer to our Privacy Policy available on London Stock Exchange’s website. Your data controller, for the purposes of applicable law, is London Stock Exchange plc.
You can access frequently asked questions on AIM.