Welcome to the latest edition of Osborne Clarke’s quoted company legal and regulatory news update.
We hope that you find it interesting. If you would like to discuss any of the content, or have a subject that you would like us to cover in the next edition, please let one of us know. Our contact details are set out below.
Jon King, Mark Wesker, Tom Harvey and Nick Thody
Market Abuse Regulation: what issuers should be thinking about now
Whilst the FCA and AIM Regulation are both still in the midst of consulting on rulebook changes to accommodate the Market Abuse Regulation, the implementation date of 3 July 2016 is fast approaching. As detailed implementing legislation from the EU starts to be issued, issuers and their advisers should begin to take steps to change internal policies and procedures to reflect the new regime. We look at what issuers should be thinking about now.
Market Abuse Regulation: AIM Regulation consults on rule changes
AIM Regulation has published AIM Notice 44, in which it consults on changes to the AIM Rules for Companies as a result of the coming into force of the MAR on 3 July 2016. We look at AIM Regulation’s proposals, and what they will mean for AIM companies if introduced.
The transparency agenda: gender pay gap reporting is coming – bonuses paid from next month will be caught
Gender pay gap reporting is expected to become law in October this year, with all employers with 250 or more relevant employees needing to comply with this new reporting requirement. Employers must take their first ‘gender pay snapshot’ on 30 April 2017 and will then have up to a year to publish the data. They will also have to publish gender pay information in respect of bonuses paid in the 12 month period prior to 30 April 2017. This means that bonus payments made from this May will potentially be caught.
Whilst final regulations have not been published, employers should start taking steps to prepare now. Taking early action is particularly important for listed companies which may have greater exposure than many to the reputational risks inherent in reporting a significant gender pay gap. Osborne Clarke is hosting a webinar on 27 April 2016 which will look at the impact of the new gender pay reporting obligation – if you would like to attend, please register using the link below.
The UK IPO process: FCA kicks off discussion on connected research and late publication of information
The FCA has released a discussion paper on the availability of information in the UK equity IPO process, focusing on the FCA’s concerns (and proposed alternative models) in relation to the perceived lack of diversity of research, and the late stage at which information is available, in a UK IPO process.
The PSC register: now in force for subsidiaries of listed companies
Whilst there is an exemption for individual companies listed on the Main Market and on AIM (which are subject to the major shareholder notification regime under DTR 5), subsidiaries of listed companies are now each under an obligation to maintain a “register of people with significant control” under this new UK transparency regime.
Whilst for many groups of companies the information going on to the register will be straightforward, the information must be filed at Companies House from 30 June 2016 – where it will be publicly available. We look at the obligations on relevant companies under this new PSC regime.
How will Brexit affect your business?
With the UK referendum on membership of the EU looking to be closer than some expected, Osborne Clarke has a dedicated microsite looking at the implications of Brexit for your business.