- ICSA Code—focus on employee share plan
- Original news
- How do the Dealing Code and accompanying Dealing Procedures Manual published recently by ICSA, QCA and GC100 (the ICSA Code) work alongside the MAR?
- How does MAR together with the ICSA Code change how share plans should be drafted and operated as compared with under the Model Code?
- The ICSA Code provides two types of closed period—MAR closed period and closed period. How do these two periods interrelate, and how will each period be applicable to the operation of share plans?
- The ICSA Code provides various exceptions to the general rule that PMDRs cannot deal in a closed period or MAR closed period. Can you summarise how these will be relevant to the operation of share plans?
- Schedule 5 of the Dealing Procedures Manual contains additional guidance on employee share plans, employee share awards and employee trusts. How does Sch 5 work alongside the main body of the ICSA Code?
- Does the release of the ICSA Code change what companies should now be doing to comply with MAR in relation to their employee share plans, or will companies wait for further FCA guidance?
Share Incentives analysis: Nicholas Stretch, partner at CMS, focuses on the employee share plans aspects of the recently published ICSA Code, a single, industry-led dealing code (replacing the Model Code) which aims to assist companies to comply with the EU Market Abuse Regulation which came into effect on 3 July 2016.
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