Are companies that list American Depositary Receipts on NASDAQ required to report the declaration of a dividend?
Yes. NASDAQ’s rules require that the listed company provide notice to NASDAQ and the public of a dividend action or stock distribution. These notifications are the responsibility of the listed company. The company can designate its Depositary Bank to complete the appropriate NASDAQ form if so desired and NASDAQ will accept the form from the bank on behalf of the issuer. However, any failure to comply with NASDAQ’s requirements remains the responsibility of the company. The company (or its designee) should use either the Notification: Cash Dividend/Distribution or the Notification: Non-Cash Dividend/Distribution to report the transaction. When reporting a cash dividend on an ADR, the information provided in the “amount” field should be the amount to be distributed to ADR holders. The company should include in this field not only the net amount of the distribution but also the gross amount and any tax and fee information. Notice on the appropriate form should be provided to NASDAQ Corpor