What is meant by “appropriate system” to prevent Officers from disposing of their holdings in a company’s securities?
An “appropriate system” is not explicitly defined within the regulations, as it is likely to depend on the company, the size of its board and the interests held by its Officers. An appropriate system that monitors and controls Officers’ dealings should be agreed upon by the company and its J-Nomad. While we thus expect that different companies will construct different systems, we envision as one example the signing of memoranda between applicable officers and the Listed Company and/or J-Nomad.
Related Questions
- Lexicon reported a lot of Undefined Terms that weren really undefined; they were just place names and the names of company officers. Why?
- Why are Officers prevented from disposing of their interests in a company’s securities for 1 year from listing?
- What is the minimum number of officers a private limited company requires?
