Issuers (or anybody operating on their behalf or for their account) must compile a list of all insiders who work for them under contract or otherwise have access to inside information (such as lawyers, accountants, investment banks, or other advisers).
Insider lists must have deal-specific or event-based sections and can also have an optional permanent insider section (Article 2, Implementing Regulation).
Insider lists must include all content specified by MAR (Article 18(3)) and be drawn up using the prescribed template (MAR, Article 2(3)).
Issuers must take all reasonable steps to ensure insiders acknowledge their duties in writing (MAR 18(2)).
Insider lists must be maintained in electronic form (Article 2(3), Implementing Regulation) and updated immediately (including when the basis for adding a person changes) (Article 18(4), MAR).
An issuer must promptly disclose an insider list to the relevant National Competent Authority upon request (MAR 18(1)c).
Insider lists must be kept for at least five years after they are created or amended (Article 18(5), MAR).
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