ABSTRACT

Through the ‘Model Code’ for transactions in securities by directors, certain employees and persons connected with them, the Listing Rules have probably served to restrain those persons who might otherwise have been most easily tempted into insider dealing. Generally, the Listing Rules also impose obligations as to the disclosures a company must make about its directors121 and set out certain requirements for transactions between a company and any of its directors.122 It is provided that a listed company must ensure that its directors accept full responsibility, both collectively and individually, for its compliance with the Listing Rules.123