Module 16 2024

23/10/2024

Delays in Disclosure

Delay in disclosing information can ● mislead investors ● expose company to share holder and product liability claims

FSA guidance ● “If a company is faced with an unexpected and significant event, a short delay may be acceptable if it is necessary to clarify the situation. In such situations a holding announcement should be used where there is a danger of inside information leaking before the facts and their impact can be confirmed.” In some circumstances, companies can delay disclosure at their own risk where it would not be misleading the public

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Responses to External Enquiries

Outside enquiries - Information disclosed (e.g. to media, financial or securities analysts, share purchasers or sellers) can give rise to liability if incomplete or misleading

Risk violation of rules against selective disclosure

Inquiries should be referred to those familiar with all relevant information and applicable rules and issues

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