This section of our website sets out the arrangements operated by the firm in relation to Article 18 of the EU Market Abuse Regulation (2014/596) and EU Commission Implementing Regulation (2016/347) (the Insider List Rules). These arrangements shall be operated whenever we act on behalf or on account of a client who is subject to the Insider List Rules in relation to information to which the firm has access and which the firm has been informed is inside information for the purposes of the Insider List Rules (Inside Information).
The firm will maintain lists as required by the Insider List Rules of persons working for Slaughter and May on behalf of a client or on a client’s account, under a contract of employment or otherwise, who have access to Inside Information (Insider Lists). The Insider Lists shall contain the information required by the Insider List Rules and will be updated as required by those rules and kept for the period required by those rules.
The firm will provide a copy of an Insider List to the Financial Conduct Authority (or other relevant EEA authority) to enable the client to meet any request made of the client by the Financial Conduct Authority (or other relevant EEA authority) pursuant to the Insider List Rules.
The firm takes the necessary measures to ensure that every person working for Slaughter and May whose name is on an Insider List acknowledges the legal and regulatory duties entailed and is aware of the sanctions attaching to the misuse or improper circulation of Inside Information. These measures include appropriate training of both legal and non-legal staff and appropriate provisions in employment contracts.
If, during the course of a matter, Slaughter and May instruct another law firm or other third party to act on behalf or for the account of a client, in circumstances where we expect them to receive Inside Information, we will, at our client's request, use reasonable endeavours to ensure that the third party in question gives the client substantially the same confirmations and acknowledgements in relation to the Inside Information and Insider Lists as are set out above. Unless a client informs us otherwise, the firm is entitled to assume that a client’s advisers and third parties who have not been instructed by the firm and who are acting on behalf or for the account of the client in relation to a matter involving Inside Information have given confirmations and acknowledgements of this kind to the client and that the firm may pass Inside Information to them in the course of the matter.