Best practices for PDMR compliance
Managing Persons Discharging Managerial Responsibilities (PDMRs) under the Market Abuse Regulation (MAR) requires a systematic approach that combines clear policies, robust systems, and ongoing education. For many organisations, the challenge lies not just in understanding the requirements, but in implementing practical, sustainable solutions that ensure consistent compliance. Here are five essential best practices that can help organizations build a strong foundation for PDMR management.
Establish a clear PDMR Policy
Companies should have a comprehensive PDMR policy outlining the roles, responsibilities, and procedures for monitoring and reporting PDMR transactions. Regular reviews and updates of this policy are essential to ensure continued compliance.
Manage Closed Periods and Trading Restrictions
Implement clear processes for managing closed periods and communicating these restrictions to PDMRs. Automated notification systems can help ensure that all PDMRs are aware of their obligations during these periods.
Implement Robust Monitoring and Reporting Systems
A robust system for monitoring PDMR transactions and reporting them to regulatory authorities is crucial. This system should facilitate the reporting of transactions, generate alerts for potential breaches, and produce reports for audits.
Provide Training and Support for PDMRs
Regular training on MAR obligations and the company’s PDMR policy is necessary. This training should cover the definition of inside information, transaction disclosure processes, and the management of closed periods.
Utilize Technology for Compliance
Leveraging technology platforms like InsiderList can simplify PDMR management. This platform automate the management of PDMRs and their closely associated persons, streamline transaction reporting, and ensure compliance with MAR requirements. By following these best practices and staying informed about regulatory updates, companies can effectively manage PDMR compliance and mitigate risks associated with market abuse.
For More information, have a look at ESMA's Q&A here ESMA70-145-111 Q&As on MAR (europa.eu)