What is the difference between insiders and PDMRs?

What is the difference between insiders and PDMRs?

There are two main categories of individuals that need to be separated: Insiders and PDMR.

Insider

The status of being an Insider is based only on access to actual inside information. A person becomes and Insider and then ceases to be an Insider when the information is no longer inside information. This is managed by creating insider lists in Logwise and adding the individuals who have access to the information. A company cannot be an insider, it is only the individuals involved who become insiders and only when they actually receive the inside information. If the person receiving inside information represents a different legal entity (not employed by the company) they are required to keep their own insider list with all the persons they share the information with. You can then add only one person from that legal entity and inform them of this obligation.

There is an option to create a list of "Permanent Insiders", however this is not required and the recommendation is to avoid using a permanent insider list if possible.

PDMR (Persons discharging managerial responsibilities)

This status is based only on what position and mandate an individual has within the company regardless of if they currently have access to inside information. These individuals should be added as PDMR in Logwise.

Logwise has produced a guide for identifying if an individual is a PDMR which also explains some of the differences to Insiders: https://www.logwise.com/insights/guide-permanent-insiders-persons-discharging-managerial-responsibilities/

For each PDMR you are also required to keep a list of their closely associates persons (PCA). This is both for individuals and companies. But the direction of the relationship for companies is not if the PCA company controls or has ownership of the company but instead if the PDMR of the company controls the PCA company. So this means that ownership in the company is not relevant, instead ownership and control by for instance a board member in other companies is what should be tracked for each PDMR. Every PCA for your PDMRs should be added in Logwise - the easiest way to do this is if the PDMR themselves log in and manage their own PCAs. 

Some useful support links for your PDMR:

Logwise has a guide detailing some of the more complex assessments that may be needed for legal entities as PCAs also: https://www.logwise.com/insights/legal-entities-persons-closely-associated-mar/



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