Post on 11-Nov-2021
Lamprellshare dealing
Code
Revision 5 | September 2021
This document is in the custody of theGroup General Counsel & Company Secretary
LAMPRELL SHARE DEALING CODE
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Contents
Introduction 4
Part A - clearance procedures 4
Part B - additional provisions for PDMRS 5
Schedule 1 - defined terms 8
APPENDIX 1 10
Letter to PDMRS relating to notifications
of dealings (plus letter to connected persons) 10
APPENDIX 2 14
Letter to permanent insiders 14
Letter to project insiders 15
Template request for authorisation form 16
Template notification of dealings form 18
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Introduction
The Purpose of this Code is to ensure that
the Directors of Lamprell plc (the Company),
and certain employees of the Company
and its subsidiaries, do not abuse or place
themselves under suspicion of abusing
Inside Information, and comply with
their obligations under the Market Abuse
Regulation.
Part A of this Code contains the Dealing
clearance procedures which must be
observed by the Company’s Person
Discharging Management Responsibilities
(PDMRs) and those employees who have
been told that the clearance procedures
apply to them. This means that there will
be certain times when such persons cannot
Deal in Company Securities.
Part B sets out certain additional obligations
which only apply to PDMRs.
Failure by any person who is subject to
this Code to observe and comply with its
requirements may result in disciplinary
action. Depending on the circumstances,
such non-compliance may also constitute a
civil and/or criminal offence.
Schedule 1 sets out the meaning of
capitalised words used in this Code, and it
is recommended you familiarise yourself
with them while reading this document.
Part A - clearance procedures
Dealing by restricted persons
If you are a Director of the Company or are
informed in writing that you are a PDMR,
you will be a ‘Restricted Person’ for the
purposes of this Code. As a Restricted
Person you must not deal in the Company’s
Shares without obtaining clearance to deal in
advance in accordance with paragraph 2 of
this Code.
Clearance to deal
You must not Deal for yourself or for anyone
else, directly or indirectly, in Company
Securities without obtaining clearance from
the Company in advance.
a. Applications for clearance to
deal must be made in writing and
submitted to the Company Secretary
using the template form ‘Template
Request for Authorisation Form’ set
out in Appendix 2.
b. You must not submit an application
for clearance to Deal if you are in
possession of Inside Information.
If you become aware that you are
or may be in possession of Inside
Information after you submit an
application, you must inform the
Company Secretary as soon as
possible and you must refrain from
Dealing (even if you have been given
clearance).
c. You will receive a written response to
your application, normally within five
business days from submission. The
Company will not normally give you
reasons if you are refused permission
to Deal. You must keep any refusal
confidential and not discuss it with any
other person.
d. If you are given clearance, you must
Deal as soon as possible and in any
event within two business days of
receiving clearance.
e. Clearance to Deal may be given
subject to conditions. Where this is
the case, you must observe those
conditions when Dealing.
f. You must not enter into, amend or
cancel a Trading Plan or an Investment
Programme under which Company
Securities may be purchased or sold
unless clearance has been given to do
so.
g. Different clearance procedures will
apply where Dealing is being carried
out by the Company in relation to
an employee share plan (e.g. if the
Company is making an option grant
or share award to you, or shares
are receivable on vesting under
a long-term incentive plan). You
will be notified separately of any
arrangements for clearance if this
applies to you.
h. If you act as the trustee of a trust,
you should speak to the Company
Secretary about your obligations in
respect of any Dealing in Company
Securities carried out by the trustee(s)
of that trust.
i. You should seek further guidance
from the Company Secretary before
transacting in:
• units or shares in a collective
investment undertaking (e.g. a UCITS
or an Alternative Investment Fund)
which holds, or might hold, Company
Securities; or
• financial instruments which provide
exposure to a portfolio of assets which
has, or may have, an exposure to
Company Securities.
This is the case even if you do not intend to
transact in Company Securities by making
the relevant investment.
Part B - additional provisions for PDMRS
Circumstances for refusal
You will not ordinarily be given clearance
to Deal in Company Securities during any
period when there exists any matter which
constitutes Inside Information or during a
Closed Period.
Notification of transactions
a. You must notify the Company and the
Financial Conduct Authority (FCA) in
writing of every Notifiable Transaction
in Company Securities conducted for
your account as follows:
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• Notifications to the Company must be
made using the template ‘Template
Notification Of Dealings Form’ below
and sent to the Company Secretary as
soon as practicable and in any event
within one business day. You should
ensure that your investment managers
(whether discretionary or not) notify
you of any Notifiable Transactions
conducted on your behalf promptly so
as to allow you to notify the Company
within this time frame.
• Notifications to the FCA must be
made within three business days of
the transaction date. A copy of the
notification form is available on the
FCA’s website.
b. If you are uncertain as to whether
or not a particular transaction is a
Notifiable Transaction, you must
obtain guidance from the Company
Secretary.
PCAS and investment managers
a. You must provide the Company with
a list of your PCAs and notify the
Company of any changes that need to
be made to that list.
b. You should ask your PCAs not to
Deal (whether directly or through an
investment manager) in Company
Securities during Closed Periods and
not to deal on considerations of a
short-term nature. A sale of Company
Securities which were acquired
less than a year previously will be
considered to be a Dealing of a short-
term nature.
c. Your PCAs are also required to
notify the Company and the FCA in
writing, within the time frames given
in paragraph 2, of every Notifiable
Transaction conducted for their
account. You should inform your PCAs
in writing of this requirement and keep
a copy; the Company Secretary will
provide you with a letter that you can
use to do this. A copy of the form for
notifying the FCA is available on the
FCA’s website. You should ask your
investment managers (whether or not
discretionary) not to Deal in Company
Securities on your behalf during
Closed Periods.
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Schedule 1 - defined terms
Closed Period means any of the following:
• the period of 60 calendar days
before the release of the preliminary
announcement of the Company’s
annual results (or, where no such
announcement is released, up to the
publication of the Company’s annual
financial report) or, if longer, the
period from the end of the relevant
financial year up to such release (or
publication); and
• the period of 60 calendar days before
the release of the Company’s half-
yearly financial report or, if longer, the
period from the end of the relevant
financial period up to such release.
Company Securities means any publicly
traded or quoted shares or debt instruments
of the Company (or of any of the Company’s
subsidiaries or subsidiary undertakings) or
derivatives or other financial instruments
linked to any of them, including phantom
options.
Dealing (together with corresponding terms
such as ‘Deal’ and ‘Deals’) means any type of
transaction in Company Securities, including
purchases, sales, the exercise of options, the
receipt of shares under share plans, using
Company Securities as security for a loan or
other obligation and entering into, amending
or terminating any agreement in relation to
Company Securities (e.g. a Trading Plan).
FCA means the UK Financial Conduct
Authority.
Inside Information means information which
relates to the Company or any Company
Securities, which is not publicly available,
which is likely to have a non-trivial effect on
the price of Company Securities and which
an investor would be likely to use as part of
the basis of his or her investment decision.
Investment Programme means a share
acquisition scheme relating only to the
Company’s shares under which: (A) shares
are purchased by a Restricted Person
pursuant to a regular standing order or
direct debit or by regular deduction from
the person’s salary or director’s fees; or (B)
shares are acquired by a Restricted Person
by way of a standing election to re-invest
dividends or other distributions received;
or (C) shares are acquired as part payment
of a Restricted Person’s remuneration or
director’s fees.
Market Abuse Regulation means the EU
Market Abuse Regulation (596/2014).
Notifiable Transaction means any
transaction relating to Company Securities
conducted for the account of a PDMR
or PCA, whether the transaction was
conducted by the PDMR or PCA or on his
or her behalf by a third party and regardless
of whether or not the PDMR or PCA had
control over the transaction. This captures
every transaction which changes a PDMR’s
or PCA’s holding of Company Securities,
even if the transaction does not require
clearance under this Code. It also includes
gifts of Company Securities, the grant of
options or share awards, the exercise of
options or vesting of share awards and
transactions carried out by investment
managers or other third parties on behalf
of a PDMR, including where discretion is
exercised by such investment managers or
third parties and including under Trading
Plans or Investment Programmes.
PCA means a person closely associated with
a PDMR, being:
a. the spouse or civil partner of a PDMR;
or
b. a PDMR’s child or stepchild under the
age of 18 years who is unmarried and
does not have a civil partner; or
c. a relative who has shared the same
household as the PDMR for at least
one year on the date of the relevant
Dealing; or
d. a legal person, trust or partnership,
the managerial responsibilities of
which are discharged by a PDMR (or
by a PCA referred to in paragraphs
(a), (b), or (c) of this definition), which
is directly or indirectly controlled by
such a person, which is set up for the
benefit of such a person or which
has economic interests which are
substantially equivalent to those of
such a person.
PDMR means a person discharging
managerial responsibilities in respect of the
Company, being either:
a. director of the Company; or
b. any other employee who has been
told that he or she is a PDMR.
Restricted Person means:
a. a PDMR; or
b. any other person who has been told
by the Company that the clearance
procedures in Part A of this Code
apply to him or her.
Trading Plan means a written plan
entered into by a Restricted Person and
an independent third party that sets out a
strategy for the acquisition and/or disposal
of Company Securities by the Restricted
Person, and:
a. specifies the amount of Company
Securities to be dealt in and the price
at which and the date on which the
Company Securities are to be dealt in;
or
b. gives discretion to that independent
third party to make trading decisions
about the amount of Company
Securities to be dealt in and the price
at which and the date on which the
Company Securities are to be dealt in;
or
c. includes a method for determining the
amount of Company Securities to be
dealt in and the price at which and the
date on which the Company Securities
are to be dealt in.
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APPENDIX 1
Letter to PDMRS relating to notifications of dealings (plus letter to connected persons)
[TO BE PLACED ON LAMPRELL plc LETTERHEAD]
TO: [Name of persons discharging
managerial responsibilities] [Address]
[Date]
Requirement to disclose dealings in
Lamprell plc’s shares and related financial
instruments pursuant to the Market Abuse
Regulation
Dear [name of individual]
Obligations are imposed on directors and
certain senior executives of listed companies
to disclose dealings in the shares and
related financial instruments of those listed
companies. The obligations also extend to
certain individuals and bodies corporate
connected to those directors and senior
executives.
These obligations are contained in the
Market Abuse Regulation (MAR). Lamprell
plc (the Company) has a number of
obligations under MAR including drawing
up and maintaining a list of all persons
discharging managerial responsibilities and
those persons closely associated with them
(PCAs). [As a director of the Company,
you are a person discharging managerial
responsibilities and MAR also applies to
you/We have decided that the disclosure
of dealings obligations contained in MAR
also apply to you as a senior executive of
the Company]. The purpose of this letter
is to explain the nature of your disclosure
obligations with which you and persons
closely associated with you (PCAs) need to
comply.
Any failure to make the necessary
disclosures under MAR may result in the FCA
taking action against you personally. The
FCA can impose an unlimited fine or publicly
censure any individual who breaches MAR.
In addition, we may consider any failure
to comply with these requirements as a
disciplinary matter.
Disclosure requirement
MAR requires you to disclose to the
Company any transactions conducted on
your own account in the shares, derivatives
or other financial instruments related to
shares of the Company. You are required to
disclose these transactions within 2 business
days of the date of the transaction.
This notification obligation is in addition
to any obligations under Chapter 5 of the
Disclosure Guidance and Transparency Rules
(Notification of the acquisition or disposal
of major shareholdings) applicable to the
disclosure of voting rights in respect of the
Company’s shares of 3% or more.
A notification form is available at [∞ ]for
this purpose. You should ensure that you
complete all the boxes as accurately and
completely as possible. Please send your
notification form to [name of relevant
individual] within 2 business days of the date
on which the transaction occurred.
You must also notify the FCA using the
online form linked below within 2 business
days of the date on which the transaction
occurred.
https://marketoversight.fca.org.uk/
electronicsubmissionsystem/MaPo_PDMR_
Introduction
Please contact Company Secretary if
you require assistance in completing the
notification form.
Types of transaction and financial instruments
You are required to disclose any transactions
conducted on your account (whether by
you or an intermediary) in the shares or
derivatives or financial instruments related
to the shares of the Company. For example,
this would cover any options over shares of
the Company or a spread bet on the price of
the shares.
You should consider the types of
transactions to be caught by your disclosure
obligations in the widest sense and not
just sales and purchases of shares. Non-
exhaustive lists of the kinds of transactions
that must be notified are set out the
memorandum attached at Attachment 1 to
this letter.
If you are in any doubt as to whether a
transaction that you propose to conduct in
the securities of the Company is caught by
this notification requirement, please contact
Company Secretary before proceeding with
the transaction.
Obligations on your connected persons
The Disclosure Rules also require certain
individuals and bodies corporate who are
connected to you within the meaning of
Schedule 11B to disclose any transactions
conducted on their own account in the
shares, derivatives and other financial
instruments related to the shares of the
Company. This obligation to disclose
dealings falls on the connected person
personally. Consequently, we require you
to inform your connected persons that they
are connected to you for the purposes of
the Disclosure Rules. In order to explain the
obligations to them, we have provided you
with a letter from you to your connected
persons setting out their obligations in
Attachment 2 of this letter.
Any of the following people will be
considered to be a person closely associated
to you for the purposes of MAR:
a. your spouse or civil partner;
b. your child or step-child under the age
of 18 years who is unmarried and does
not have a civil partner;
c. any relative who has shared the same
household as you for at least one year;
or
d. legal person, trust or partnership:
• the managerial responsibilities of
which are discharged by you or by any
person referred to in (a) - (c) above;
• which is directly or indirectly
controlled by such a person;
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• which is set up for the benefit of such
a person; or
• the economic interests of which are
substantially equivalent to those of
such a person.
If you are unsure whether a person or entity
might be considered to be a PCA, please
contact Company Secretary.
The FSA has stated that the last category
of connected persons will only include
companies of which you (or your connected
persons) are a sole director or where you
(or your connected persons) personally
have the power to control the company’s
management decisions affecting its future
development and business prospects, rather
than merely being able to exert influence.
Consequently, if you are on the Board of
Directors of another listed company, for
example, that listed company will not be one
of your connected persons.
Please fill in the PCA Questionnaire attached
at Attachment 3 of this letter with details of
your PCAs and email the list to Company
Secretary as soon as possible.
Share Dealing Code
The Company’s Share Dealing Code outlines
the obligation on you to seek clearance
before you deal in any securities of the
Company and to refrain from dealing in
certain periods.
In particular, you should seek to prohibit
your PCAs from dealing in closed periods
or on considerations of a short term nature.
You must also advise your PCAs of the fact
that you are a person discharging managerial
responsibilities at the Company, of the
closed periods during which they cannot
deal in the securities of the Company
and that they must advise the Company
immediately after they have dealt in the
Company’s securities.
Yours sincerely
…………………………………….……….……….
For and on behalf of Lamprell plc
Approved by:
Alex Ridout
Group General Counsel & Company
Secretary
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APPENDIX 2
Letter to permanent insiders
[TO BE PLACED ON LAMPRELL plc LETTERHEAD]
CONFIDENTIAL – ADDRESSEE ONLY
Permanent Insider List
This is to inform you that you have been
designated a Permanent Insider by the
Company’s Disclosure Committee and are
subject to the Company’s Share Dealing
Code. The Share Dealing Code can be found
at [ ].
As you will see from the Share Dealing
Code, Permanent Insiders must first obtain
approval from [the Chief Executive/Chairman
– amend according to role of the Permanent
Insider] or a designated director before
dealing in the Company’s shares. Save in
exceptional circumstances, clearance to deal
will only be given if no inside information
relating to the Company is in existence and
the Company is not in a ‘closed period’. If
you wish to deal in shares of the Company,
you should apply for clearance on the Form
entitled ‘Request for Authorisation to Deal
in Securities of Lamprell plc’. You should
also familiarise yourself with the Company’s
Disclosure Policy and Insider Dealing and
Market Abuse Policy.
Please ensure that all inside information
to which you have access is treated as
confidential and not conveyed by you to any
third party except where:
(i) the express consent of the Disclosure
Committee has been obtained; or
(ii) the Disclosure Committee has
determined that the Company is
permitted to delay public disclosure
of the inside information and the
disclosure is to an adviser of the
Company and is for a legitimate
purpose and such adviser is bound by
appropriate duties or obligations of
confidentiality to the Company.
You should not pass any inside information
to any other employees of the Company
other than those who require it to perform
their role.
You have been designated a Permanent
Insider and been placed on the Permanent
Insider List due to the nature of your role
in the Company and the fact that you
regularly or occasionally have access to the
Company’s inside information. If you move
roles or resign from your employment or
office please inform the Company Secretary.
If you require clarification on this note,
please contact the Company Secretary.
Please sign and return the enclosed copy
of this letter to the Company Secretary to
acknowledge your agreement to comply
with the terms of this letter.
………………………………………………………
For and on behalf of Lamprell plc
Date:
Letter to project insiders
[TO BE PLACED ON LAMPRELL plc LETTERHEAD]
CONFIDENTIAL – ADDRESSEE ONLY
Project Insider List
As you are aware, you are a member of the
team of Project [ ] (the Project). The
existence of the Project, and of information
generated from time to time from it, may
constitute inside information. Consequently,
you have been designated a Project Insider
and are subject to the Share Dealing Code
of Lamprell plc’s (the Company). The Share
Dealing Code can be found at [∞].
As you will see from the Share Dealing Code,
Project Insiders must first obtain approval
from [the Company Secretary – amend
according to the role of the Project Insider]
or a designated director before dealing in
the Company’s shares. Save in exceptional
circumstances, clearance to deal will only be
given if no inside information relating to the
Company is in existence and the Company is
not in a ‘closed period’. If you wish to deal
in shares of the Company you should apply
for clearance on the Form entitled ‘Request
for Authorisation to Deal in Securities of
Lamprell plc’. You should also familiarise
yourself with the Company’s Disclosure
Policy and Insider Dealing and Market Abuse
Policy.
Please ensure that the details and
existence of the Project and all other inside
information to which you have access is
treated as confidential and not conveyed by
you to any third party except where:
(i) the express consent of your Project
Leader or the Disclosure Committee
has been obtained; or
(ii) the Project Leader has designated
that third party as a member of the
Project team who requires the inside
information to perform his/her role; or
(iii) the Disclosure Committee has
determined that the Company
is permitted to delay the public
disclosure of the inside information
and, with the express consent of your
Project Leader, the disclosure is to an
adviser of the Company and is for a
legitimate purpose and such adviser
is bound by appropriate duties or
obligations of confidentiality to the
Company.
You should not pass any inside information
to any other employees of the Company
other than those who require it to perform
their duties and are a member of your
Project team.
If you leave the team working on the Project
or resign from your employment or office
please inform your Project Leader.
If you require clarification on this note,
please contact the Company Secretary.
I will write to you again in due course to let
you know when you are no longer subject to
the dealing Code.
Please sign and return the enclosed copy
of this letter to the Company Secretary to
acknowledge your agreement to comply
with the terms of this letter.
………………………………………………………For and on behalf of Lamprell plc
Date:
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TEMPLATE
REQUEST FOR AUTHORISATION TO DEAL IN SECURITIES OF
LAMPRELL PLC (the Company)
Request from:
Request to:
I request authority to deal in Lamprell plc ordinary shares as follows:
Transaction Details:
Description of securities:
Number of securities:
Nature of the dealing:
Other details:
Name:
Location:
Contact details:
My position in the Company:
My department:
Chairman/Chief Executive/Company Secretary (please delete as
appropriate *)
[e.g. a share, a debt instrument, a derivative or a financial
instrument linked to a share or debt instrument.]
[If actual number is not known, provide a maximum amount (e.g.
‘up to 100 shares’ or ‘up to £1,000 of shares’).]
[Description of the transaction type (e.g. acquisition; disposal;
subscription; option exercise; settling a contract for difference;
entry into, or amendment or cancellation of, an investment
programme or trading plan).]
[Please include all other relevant details which might reasonably
assist the person considering your application for clearance (e.g.
transfer will be for no consideration).]
[If you are applying for clearance to enter into, amend or cancel
an investment programme or trading plan, please provide full
details of the relevant programme or plan or attach a copy of its
terms.]
*Note (i) Employees should apply to the Company Secretary; (ii) the Chairman should apply to the Chief Executive (or, if not present, the Senior Independent Director, Board Committee or other nominated Director) (iii) the Chief Executive should apply to the Chairman (or, if not present, the Senior Independent Director
I confirm that the information I have provided is accurate and understand that the Company
is relying on the accuracy of such information in considering my request for authorisation to
deal. I also understand that the Company will consider my request and its obligations under the
Market Abuse Regulation and will respond as soon as reasonably practicable within a period of 5
business days of the request being made.
My immediate manager:
Your signature: Date:
Authorisation to deal given/not given by:
Name: Signature:
Title: Date:
I confirm that: Please tick
a. I have read and understood the Share Dealing Code which is available at [∞].
b. I am not and will not in breach of the Share Dealing Code in relation to this transaction
This authority is valid for TWO WORKING DAYS excluding the date of authorisation. If you
do not deal within the two day period you will need to get a new authority to deal.
If you are a Director or a Person Discharging Managerial Responsibilities or a Person
Closely Associated with a Director or a Person Discharging Managerial Responsibilities,
please supply to the Company Secretarial department, without delay following the
transaction, a completed copy of the Form entitled ‘Notification of Transaction by a PDMR
or Person Closely Associated with a PDMR’.
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NOTIFICATION FORM OF DEALINGS IN SECURITIES OF
LAMPRELL PLC (the Company)
Notification to:
Description of the financial instrument
Nature of the transaction
Details of PDMR/PCA: Name:
[Include first name(s) and last name(s).]
[If the PCA is a legal person, state its full name including legal
form as provided for in the register where it is incorporated, if
applicable.]
Position/Status:
[For PDMRs, state job title e.g. CEO, CFO.]
[For PCAs, state that the notification concerns a PCA and the
name and position of the relevant PDMR.]
Initial notification/amendment:
[Please indicate if this is an initial notification or an amendment
to a prior notification. If this is an amendment, please explain the
previous error which this amendment has corrected.]
Chairman/Chief Executive/Company Secretary (please delete as
appropriate *)
[e.g. a share, a debt instrument, a derivative or a financial instrument linked to a share or debt instrument.]
[Description of the transaction type e.g. acquisition, disposal, subscription, contract for difference, etc.][Please indicate whether the transaction is linked to the exercise of a share option programme.][If the transaction was conducted pursuant to an investment programme or a trading plan, please indicate that fact and provide the date on which the relevant investment programme or trading plan was entered into.]
:
:
Details of the transaction(s):
section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each
date; and (iv) each place where transactions have been conducted
*Note (i) Employees should apply to the Company Secretary; (ii) the Chairman should apply to the Chief Executive (or, if not present, the Senior Independent Director, Board Committee or other nominated Director) (iii) the Chief Executive should apply to the Chairman (or, if not present, the Senior Independent Director
Aggregated information [Please aggregate the volumes of multiple transactions when these transactions:
• relate to the same financial instrument;
• are of the same nature;
• are executed on the same day; and
• are executed at the same place of transaction.] [Please state the
metric for quantity.]
[Please provide:
• in the case of a single transaction, the price of the single transaction;
and
• in the case where the volumes of multiple transactions are
aggregated, the weighted average price of the aggregated
transactions.]
[Please state the currency.]
:
Date of transaction [Date of the particular day of execution of the notified transaction, using the date format: YYYY-MM-DD and please specify the time zone.]
:
Place of transaction [Please name the trading venue where the transaction was executed. If the transaction was not executed on any trading venue, please state ‘outside a trading venue’ in this box.]
:
Price(s) and Volume(s)
[Where more than one transaction of the same nature (purchase, disposal, etc.) of the same financial instrument are executed on the same day and at the same place of transaction, prices and volumes of these transactions should be separately identified in the table above, using as many lines as needed. Do not aggregate or net off transactions.]
[In each case, please specify the currency and the metric for quantity.]
Price(s) Volume(s):TEMPLATE
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I confirm that the information I have provided is accurate and understand that the Company
is relying on the accuracy of such information in considering my request for authorisation to
deal. I also understand that the Company will consider my request and its obligations under
the Market Abuse Regulation and will respond as soon as reasonably practicable within a
period of 5 business days of the request being made.
Your signature: Date:
This authority is valid for TWO WORKING DAYS excluding the date of authorisation. If you
do not deal within the two day period you will need to get a new authority to deal.
If you are a Director or a Person Discharging Managerial Responsibilities or a Person
Closely Associated with a Director or a Person Discharging Managerial Responsibilities,
please supply to the Company Secretarial department, without delay following the
transaction, a completed copy of the Form entitled ‘Notification of Transaction by a PDMR
or Person Closely Associated with a PDMR’.
Hamriyah Free Zone, Sharjah
P.O. Box 42149, Sharjah
United Arab Emirates
T: +971 6 528 2323
F: +971 6 528 4325
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