When should a legal entity be added as an Associate?

When should a legal entity be added as an Associate?

MAR should be read to cover those cases where a PDMR within an issuer (or a closely associated natural person) takes part in or influences the

decisions of another legal person, trust or partnership (hereinafter “legal entity”) to carry out transactions in financial instruments of the issuer.

For example, in the case of mere cross board membership, where a person sits in the administrative, management or supervisory body of an issuer and also in the board of

another legal entity where they exercise executive or non-executive functions, without however taking part nor influencing the decisions of that legal entity to carry out

transactions in financial instruments of the issuer, then that person should not be considered discharging managerial responsibilities within that legal entity for the

purposes of Article 3(1)(26)(d) of MAR. Therefore, that legal entity should not be subject to the notification obligations under Article 19(1) of MAR, *unless it is directly

or indirectly controlled by, is set up for the benefit of, or its economic interests are substantially equivalent to those of that person.*


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