ACTION S.A. is an issuer whose financial instruments (shares) have been admitted to trading on regulated markets of the Warsaw Stock Exchange. In view of the above, ACTION S.A. is obliged to apply Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (Market Abuse Regulation) and repealing Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC ("MAR Regulation").
Therefore, persons holding managerial positions in the Issuer’s structure and persons closely related to them are obliged to notify ACTION S.A. and the Polish Financial Supervision Authority about transactions made on their own account on the Issuer’s financial instruments.
Persons holding managerial positions and persons closely related to them are obliged to notify ACTION S.A. and the Polish Financial Supervision Authority of each subsequent transaction when the total amount of EUR 5,000 is achieved during one calendar year. The EUR 5,000 threshold is calculated by adding up without netting the positions of all transactions referred to in section 1 Article 19 of the MAR Regulation.
Such notifications shall be made immediately and no later than three business days after the transaction date.
A template of the notification of transactions made by the Issuer ACTION S.A. and the Financial Supervision Authority is available HERE.
The position of the Office of the Polish Financial Supervision Authority on the manner of completing transaction notifications is available HERE.
A scan of signed notifications should be sent to the following e-mail addresses:
ACTION S.A.: olga.gams@action.pl i krzysztof.bialy@action.pl
KNF: 19mar.knf.gov.pl
Close associate means:
- a spouse or partner considered by national law as equivalent to a spouse;
- a dependent child in accordance with national law;
- a family member who, at the date of the transaction, remains in the same household for at least one year; or
- a legal person, a group of undertakings or a partnership in which the managerial responsibilities are exercised by a person discharging managerial responsibilities or by a person referred to in points (a), (b) or (c) over which that person has direct or indirect control which is created to benefit that person or whose economic interests are substantially in line with those of that person.