- Â Sense, purpose and scope.
1.1. The present internal regulation of conduct (hereinafter “Regulations“) is a consequence of provisions of law 24/1988, of July 28, the stock market (hereinafter referred to as the “LMV“), in the Royal Decree 1333 / 2005 of 11 November (hereinafter “Royal Decree“) and in the other regulations of development.
1.2. This regulation is configured as an internal standard for basic enforced by competent persons to that referred to in the following paragraph 1.3 and contributes to establishing the principles that regulate the performance of TECHRULES, S.A. (hereinafter referred to as the “society“).
1.3. This regulation is applicable to the following persons (hereinafter referred to as “Relevant persons“):
â€¢ The society.
â€¢ The members of the Board of Directors of the company (when the members of the Board of Directors is a legal person, the rules of procedure shall apply to individuals representatives of those on the Board of Directors).
â€¢ The directors of the society.
â€¢ Employees of the company with respect to those sections that could be them applied as a result of charges that occupy and the roles played.
â€¢ In the event that any, agents, advisors representatives and external professionals who have access to privileged information and during the period of time deemed it as such.
1.4 Provided that there are circumstances that justify it and permitted by the rules of application, the body described in paragraph 11 below (hereinafter “Body” of tracking) can be so motivated, exempt from the scope of application of this regulation to any of the people listed above.
1.5. When necessary the body tracking and without prejudice to measures established by contract, this Regulation may be extended, in whole or in part, to entities that provide services under a contract for outsourcing or delegation, or any natural person whose services are put at the disposal and under the control of the company.
1.6. The monitoring of the regulation body will keep properly updated and dated a registration of competent persons.
1.7 Are included in the scope of this regulation all the Securities and financial instruments that referred to in article 2 of the LMV.
- General principles.
2.1. Â Competent persons must meet, meet and collaborate in the application of legislation and regulation that affect your specific field of activity.
2.2. Â The performance of competent persons in the exercise of their functions in the society will be based on strict adherence to and compliance with the following general principles and obligations:
â€¢ Develop orderly and prudent, management, taking care of the interests of customers as if they were themselves.
â€¢ Act with diligence, transparency and impartiality, and loyal, professionally and impartially, without putting the interests of their clients and in defense of the integrity of the market and the smooth functioning of this.
â€¢ Ensure equal treatment between customers, avoiding giving priority to a to others distributing recommendations and reports.
â€¢ Comply with the policy for managing conflicts of interest contained in this regulation.
â€¢ As a general rule, keep adequately informed customers of fair, clear and not misleading and, in particular, record at all times against them of any potential conflict of interest in relation to the financial analysis that develops.
â€¢ Ensure that each area of the company take their own decisions autonomously, establishing the necessary Chinese barriers to information.
â€¢ Get customers the information and documentation necessary for correct identification.
â€¢ Act with care, diligence, and good faith on the best terms for customers and following their instructions and market applications.
â€¢ Comply with the requirements of resources, facilities and procedures contained in this regulation.
3. General prohibitions.
3.1. In no circumstances competent persons will be actions that may involve a breach of this regulation or legislation or which in any other way, may adversely affect the reputation of the society.
3.2. Under no circumstances competent persons carry out any of the following actions:
â€¢ Improper use of privileged information.
â€¢ Prepare or develop any practices that distort the free formation of prices.
â€¢ Carry out operations prohibited personal.
â€¢ Encourage conflicts of interest.
â€¢ Hide information to the monitoring body in particular on (the existence of insider, operations personnel) and potential conflicts of interest or any other way to prevent or hinder this to properly develop its functions.
4. Assets and capabilities.
4.1. Competent persons must organize and control your media in a responsible manner, adopting the necessary measures and using the appropriate resources to carry out its activity. In this sense:
â€¢ The administrative and accounting procedures have to be necessary for the proper control of the development of the activity of reporting of investment and financial analysis or other forms of general recommendation relating to transactions in financial instruments (hereinafter referred to as the “general recommendations“).
â€¢ There shall be checks and appropriate measures for the purposes of that competent persons comply with the regulations of the stock market that is applicable to them and specifically with this regulation.
â€¢ The society will have to put the necessary means, in the event of termination or interruption of elaboration of general recommendations, the interests of their clients are not affected, and must have appropriate contingency plans.
4.2. The company shall establish measures to impede the flow of privileged information between its different areas of activity, so to ensure that each of these autonomously take decisions relating to the field of securities markets, and also avoid conflicts of interest. In particular:
â€¢ The organ of administration or, by delegation, the monitoring body, will establish separate areas of activity within the society (or the group to which they belong, provided that they act simultaneously in several of them) and appoint a responsible person who shall ensure compliance with the provisions in this paragraph 4.2 and under following 6.4 in each. In particular, it shall constitute as separate areas, at least, those required by article 83 of the LMV, legislation development or any other that will replace it in the future.
The monitoring body will maintain a list of persons corresponding to each separate area and disseminate it among competent persons, so that all are aware of this.
â€¢ The Board of Directors and the head of each Department shall establish appropriate barriers between each separate area and the rest of the organization or group and between each of the separate areas, according to the characteristics of the operations involving and information using.
â€¢ The Board of Directors will define a set of decision on investment that ensures that these be taken autonomously within the separate area.
â€¢ The transmission of insider between separate areas when it is essential for the proper development of the functions of some of them, of a particular operation or for the adoption of a decision and provided that such transmission has the authority of the monitoring body and be included in the lists will only be possible to that referred to in the following paragraph 6.5. Competent persons and organs located hierarchically above the makers of separated areas, including committees or bodies that may be responsible for this part or a person designated by him, shall be considered separate areas exceeding common structure. Within the framework of the relevant decision-making processes, may be transmitted Insider competent persons located hierarchically above the barriers, provided it knowledge to the body monitoring and this update the list referred to in the following paragraph 6.5.
5. Obligations of information.
5.1. In General and in information society direct to their customers (including advertising character) the following requirements shall be respected:
â€¢ Must be impartial, clear, correct, accurate, not misleading and delivered in time to avoid its incorrect interpretation. In this sense, advertising communications must be identified clearly as such.
â€¢ Represent the opinion of the society and must be based on objective criteria.
â€¢ It will include, in understandable manner adequate information about the society, with special emphasis on the development of generic recommendations service.
5.2. The generic recommendations shall arise in an impartial manner, informed and make special emphasis on:
â€¢ The facts are clearly distinguished from interpretations, estimates, opinions and other types of non-factual information.
â€¢ All sources of which obtained the quantitative elements that configure to get the generic recommendations is reliable. In the event that there is any doubt about the reliability of such sources, clearly such circumstance shall be indicated.
â€¢ Clearly indicated as such projections, forecasts and objectives of prices, indicating likewise and if the relevant assumptions made to develop them or use them.
â€¢ Which, if any, can be explained reasonably.
5.3 In particular and in order to keep adequately informed customers, shall:
â€¢ Record in place of the generic recommendation that does not constitute an offer for sale or subscription of securities.
â€¢ Include is clear and emphasized the identity of the departments and positions of the generic recommendation makers (parameterized software that generates it), as well as the company’s full name.
â€¢ Include the major sources used for the preparation of general recommendations and indicate if the generic recommendation has revealed the issuer whose value/financial instrument has been the subject of analysis and if such recommendation has been amended prior to its dissemination.
â€¢ Summarize the basis of assessment and the methodology used to analyze a value, a financial instrument or an issuer of these, or to set a target price for a value or financial instrument.
â€¢ Adequately explain the meaning of any recommendation made as a result of the parameterization of the quantitative items (buy, sell, maintain, time horizon of the investment to which refers the recommendation, etc.), indicating, in addition, any timely warning about risks, including, where appropriate, the sensitivity analysis of the relevant assumptions.
â€¢ Reference to the expected frequency of the updating of generic recommendation and, where appropriate, any significant change in the previously-announced hedging policy.
â€¢ Indicate in clear and prominent manner the date at which the generic recommendation is taken by relevant to the price of any value or financial instrument mentioned first, as well as the date and time.
â€¢ When a generic recommendation made by society differs from another reference to the same value, issuer or financial instrument, carried out over the period of 12 months immediately preceding their development, this change together with the date of the earlier recommendation are indicated clearly and outstanding.
5.4. In addition, where appropriate, and in order to properly manage the potential conflicts of interests of society, the members of the administrative bodies, managers and people who have participated in the elaboration of general recommendations (“relevant persons”), is to inform clearly and outstanding the following information:
â€¢ As a general rule and with regard to relevant persons and/or legal persons related, circumstances which could reasonably endanger the objectivity of generic recommendations, relevant linkages with the issuer, including the commercial, major financial interests and all relevant conflicts of interest.
â€¢ Interests or conflicts of interest of the company or of related legal persons, that are accessible, or that can reasonably be as accessible to the people responsible for generating generic recommendation.
â€¢ Interests or conflicts of interest of society, or of related legal persons known to persons who, although they have not participated in the elaboration of the generic recommendation or report, had or could reasonably be expected is that they had access to this prior to its dissemination to customers or the public.
â€¢ Stable participation that society or its Group entities maintain or go to the issuer or the company under analysis.
â€¢ Significant investments that may exist between the relevant people or any entity related, on the one hand, and the issuer, on the other hand, being considered as significant shareholdings, exceeding 5% (except for the listed companies will be 1%), direct or indirect, of relevant persons and legal persons related in the issuer and vice versa.
â€¢ Where appropriate, a statement that indicated that the relevant person or any related legal person is part on an agreement with the issuer relating to the production of the recommendation.
â€¢ Where applicable, a statement that indicated that the relevant person or any related legal person is a market maker or a supplier of liquidity, under a commitment to that effect, the financial instruments of the issuer.
â€¢ Where applicable, a statement that indicates that the relevant person or any related legal person has been Director or co-director, institution during the previous 12 months, any public offer of financial instruments of the issuer.
â€¢ When appropriate, a declaration which stated that the relevant person or any related legal person is party to any other agreement with the issuer relating to the provision of investment banking services, provided that this does not involve the disclosure of any confidential commercial information and the agreement would have been effective during the 12 previous months or had given rise during the same period to the payment of a compensation or to the promise of receiving compensation.
â€¢ The family links of relevant persons with customers or companies on which related to the generic recommendations. You will have consideration of family bonding when the spouses (or any person connected to this by a relationship of affection similar to the conjugal under national law) and the relationship to the second degree by consanguinity or affinity (ascendants, descendants, brothers and spouses of these or anyone linked to them in accordance with national law by a relationship of analogous to the conjugal affection) exercising positions of management or direction in companies over which related to the generic recommendations.
â€¢ Other financial interests or important linkages to relevant people or any entity linked with respect to the issuer required by the legislation of application coming.
5.5. In the event that the compliance with the provisions in points 3 Â°, 4 Â° and 5 Â° of paragraph 5.3 and previous 5.4 is disproportionate in relation to the breadth of the generic recommendation that has spread, it is sufficient to make reference in the report to the place where the public can have easy and direct access to the required information.
6. Abuse of market.
6.1. Competent persons shall not engage or promote conduct which, by involving the use or improper transmission of insider or market manipulation, could constitute market abuse.
6.2 Shall be deemed Insider described in article 81.1 of the LMV and Royal Decree (the “Insider“), i.e., any concrete information that relates directly or indirectly to one or more securities or financial instruments falling within the scope of the LMV or to one or several issuers of such securities or financial instruments that is it has not made public and that made or have been made public, it could influence or it would have influenced significantly on your quote. For the purposes of the provisions of the aforesaid legal article, means included in the concept of contribution, as well as for the securities or financial instruments, the value of derivative financial instruments related to those. In addition, the foregoing shall apply to securities or financial instruments with respect to which a request for admission to trading on a market or organized system of procurement is covered.
Shall be considered that information can influence significantly on the quotation when such information which could use an inverter that is reasonable as part of the basis of his investment decisions.
Furthermore, that information is concrete in nature if it indicates a set of circumstances that occur, or you can expect reasonably that they give, shall be deemed or an event has occurred, or that can reasonably be occur, when that information is sufficiently specific to allow that he could manage to conclude the possible effect of that set of circumstances or facts about the prices of securities or related financial instruments or , where appropriate, of the derivative financial instruments related to those.
6.3. The competent people who have insider may not perform or promote the accomplishment of any of the following behaviors:
â€¢ Prepare or perform any operation on the securities or financial instruments which the information relates, or any other value, financial instrument, or contract of any type, negotiated or not in a secondary market, having as underlying securities or financial instruments to which the information relates. The preparation and implementation of operations whose existence constitutes, in itself, the privileged information as well as the operations carried out in fulfillment of an obligation, now expired, acquire or transfer securities or financial instruments, when this obligation is contemplated in an agreement until the person subject concerned is in possession of privileged information is excepted, or other operations in accordance with the applicable regulations.
â€¢ Communicate such information to third parties, except in the normal exercise of their work, profession or position.
â€¢ Recommend a third party on the basis of such information that acquire yield securities or financial instruments or make others to acquire them or give.
6.4 In addition, the competent persons must: (i) communicate the existence of the privileged information to the monitoring authority, (ii) not to use self-serving and not to transmit to people outside their separate area the above-mentioned Insider as well as (iii) safeguard the privileged information, possessing, taking appropriate measures to avoid that such information may be subject to abusive or unfair use and know that this has occurred, those necessary to correct the consequences of this have been derived. In particular, measures shall be taken so that external consultants and professionals also adequately safeguard the privileged information to which access to provide services to society, and responsible for each area shall provide the necessary security measures so physical and telematic brackets that contain privileged information are preserved from access by unauthorized persons.
6.5 The monitoring body shall draw up and keep up-to-date a list of securities and financial instruments on which the company has Insider and will also take a relationship of people, internal or external, that access every privileged information, including: to) his identity; (b) the date that each of them met the information; (c) the motive which appear on the list; and (d) the dates of creation and updating the list. The above list should update when a change occurs on the grounds that a person has in it, when it is necessary to add a new person to the list, or when a person included in the list have access to privileged information, in which case proof of the date in which this occurs will be left. The monitoring body informs expressly to persons included in the list of the nature of the information and its duty of confidentiality and prohibition of their use, as well as offences and sanctions arising from its misuse. Also, inform the ends foreseen in the legislation of protection of data of a Personal nature. They shall be kept the data entered in the registers and listings provided for six years after having been enrolled or updated for the last time. They must also put at the disposal of the National Commission of the stock market when its request.
6.6. Without prejudice to provisions of the applicable regulations, for the purposes of the activity of generic advice developed by the society, he is considered as market manipulation practices that distort the free formation of prices and, in particular, it is prohibited:
â€¢ The dissemination of information through the media, including the Internet, or through any other means that provide or may provide indications false or misleading regarding the securities or financial instruments, including the spread of rumors and news that are false or misleading, when the person who disclosed them knew or would have known that the information was false or misleading.
â€¢ Take advantage of access occasional or periodic media traditional or electronic to stating an opinion about a value or financial instrument, or indirectly about its issuer, after having taken positions on that value or financial instrument and have benefited, therefore, of the impact of the expressed opinion about the price of that value or financial instrument without giving notice at the same time that conflict of interest to the public in a proper and effective way.
7. Personal operations.
7.1. Any transaction on their own on the securities or other financial instruments described in article 2 of the LMV made by a relevant person, by persons who, although they have not participated in the elaboration of the generic recommendation, had or could reasonably be expected is that they had access to this prior to its dissemination to customers or the public or by any other competent person included in listings or records described in paragraph 6.5 above (the “operations Personal”) shall be subject to the provisions of this paragraph 7.
7.2 Shall be considered personal proprietary trading by persons described in paragraph 7.1 above and:
â€¢ Your spouse (or any person connected to this by a relationship of affection similar to the conjugal, in accordance with national legislation).
â€¢ Children or stepchildren who are in charge of.
â€¢ Those other relatives who live with him or are dependent, as a minimum, one year before the date of completion of the transaction.
â€¢ Any legal person or any legal trust in which managers or administrators or business that control directly or indirectly (by having directly or indirectly 20% or more of the voting rights or of the capital or have a controlling relationship under the terms of article 4 of the LMV).
â€¢ Brought people (those that, in their own name, to conduct transactions on the securities on behalf of persons described in paragraph 7.1 above, presuming such a condition in those to whom these people to leave wholly or partially covered by the risks inherent in transactions carried out).
â€¢ Person whose relationship with the people described in the previous paragraph 7.1 is such that they have an interest, direct or indirect, significant in the result of the operation (not means that there is no interest by the mere payment of fees or commissions for the execution of the transaction).
7.3 They are excluded from the obligations contained in this section 7:
â€¢ Public debt securities transactions, as well as the operations carried out on the units or shares in collective investment institutions, harmonized or that are subject to monitoring in accordance with the legislation of a Member State establishing a level equivalent to Community legislation in terms of the distribution of risks between assets, provided that the competent person or any other person on whose behalf the operation is carried out do not participate in the management of the institution, such and as this is defined in the 64.a article) the regulation of the law 35/2003, 4 November, collective investment institutions, approved by the Royal Decree 1309 / 2005 of 4 November.
â€¢ Orderly transactions, without any intervention of persons described in paragraph 7.1 above, per, duly qualified entities, to which such persons have entrusted discretionary management of a securities portfolio. The existence or conclusion of contracts with third-party management shall report to the monitoring body, who may request information at any time from the Manager on the evolution of managed portfolios and the operations carried out.
7.4. At the request of the monitoring body of the regulation, persons described in paragraph 7.1 above shall inform at any time, in detail and, if so requested, in writing, of your personal operations.
Also within the first ten days of each quarter natural persons described in paragraph 7.1 previous carried out during the previous quarter operations personnel on their own, be handed to the monitoring organ of the regulation related to them, identification of financial instruments contracted and in accordance with the model and procedure that society has established for that purpose. If not had operated a negative declaration will be formulated. In this sense, and in General not necessary prior authorization from the mentioned monitoring body.
The monitoring body of the regulation shall be required to ensure the confidentiality of information received and communications. The same duty of confidentiality affect the members of the Board of Directors in the event that they have knowledge of them pursuant to this number.
7.5. In addition to the foregoing, and except for express authorization from the Control Authority (authorizations will be valid for one month from the moment of its reception), persons described in paragraph 7.1 above may not:
â€¢ Carry out operations staffs or negotiate on behalf of any person (including the company) with the instruments on which you are performing a specific analysis to that concern is the generic recommendations or on any other related financial instrument during the Middle since they know the conclusions of the analysis or the date of the generic recommendation and/or its likely content until the recipients of reports are received and have been able to act on the matter (this principle will not be applicable when the decision have their origin in commitments or rights acquired prior to or in operations covering such commitments, provided that the decision is not based on knowledge of the results of the generic recommendation).
â€¢ Carry out operations staffs or negotiate on behalf of any other person (including the company) with the instruments referred to in the general recommendations or any other related financial instrument in the opposite direction than indicated in these reports outside the period described in the previous point.
â€¢ Carry out operations personnel on the securities or financial instruments that, as described in paragraph 6 above, or for any other reason, the monitoring body includes in a list of values, and prohibited instruments (cited listing should be known by those affected).
8. Conflicts of interest.
8.1. In General, and in order to avoid possible conflicts of interest, the competent persons shall:
â€¢ At all times its activity with diligence, transparency and in the interest of its customers. Therefore, if in connection with the operation of generation of generic recommendations, competent people collect any fees or Commission or receive any non-monetary benefits that do not comply to the provisions of the regulations of the stock market, be deemed that his performance is not developed in accordance with the principles of diligence, transparency and defence of the interests of its clients.
â€¢ Requiring that, where generated generic recommendations for clients with conflicting interests or that carried out activities that could come into conflict, these reports or activities are supervised by different people.
â€¢ Determine and make sure that if you develop different activities that could come into conflict, the remunerations of competent persons dedicated to each of them are unrelated to the results of the activities and vice versa.
â€¢ Comply with information obligations listed in paragraph 5 of this regulation.
â€¢ Comply with the regulation of personal operations contained in paragraph 7 above.
8.2. With the same purpose, any competent people can:
â€¢ Soliciting or accepting gifts or incentives, direct or indirect of those that have a relevant interest in the generic recommendation and whose purpose is to influence operations that can develop direct or indirect recipients of this or that generate or that they can create conflicts of interest with other clients, whether it’s distorting the criteria for parameterization of the quantitative elements that generate such generic recommendations , whether it is violating the discretion due or any other unjustified cause. In this sense, people who are competent in any case may be accepted, the emitting object of analysis or providers, gratuities, signs of hospitality, or gifts, which, by its characteristics, estimated value, frequency etc., can influence the behavior of everyone who receives them and on their duty to act at all times with honesty, fairness and professionalism. In this sense, the gifts of estimated value exceeding 300 euros (â‚¬ 300.-), or multiple attentions of less than the figure in the same person, must be reported to the monitoring body, which will decide, your acceptance, or not, on both the use or destination of the same.
â€¢ Commit to give favorable reports with broadcasters that it relates to generic recommendations.
â€¢ Mislead the recipients of generic recommendations to the conduct of any legal trade on the value, instrument or issuer subject to analysis with the sole purpose of getting the benefit.
â€¢ Allow other competent people who do not have parameterized software that generate generic recommendations or issuers refer to which these reports review these reports prior to public dissemination, except to verify that the society complies with its legal obligations, if you include a recommendation or a target price.
8.3. In order to prevent conflicts of interest and to properly inform customers, relevant people will be permanently made before the monitoring organ of the regulation and keep updated, a statement on the potential conflicts of interests described in paragraph 5.4 above.
The Declaration will also include the links other than those expressed that, in the opinion of an outside observer and even-handed, could compromise the impartial performance of a relevant person and create potential conflicts of interest. In case of reasonable doubt in this respect, the relevant people should refer to the monitoring body of the regulation.
9.1. Competent persons will not be able, without knowledge of the society use the confidential information obtained by them in the society or, in general, the confidential information obtained by it, for its own benefit, nor directly or providing it to third parties. For these purposes all information obtained under the professional commitment of confidentiality refers to confidential information and with respect to which there is no general knowledge on the market.
9.2 Will be payable of competent persons the maximum diligence in the custody and treatment of the confidential information, so they may require not only responsibility for express and intentional communication of sensitive data, but also when such dissemination is carried out by a third party, but it has its origin in a negligent or culpable conduct of competent persons.
9.3. The relationships that keep customers with the society are based primarily on trust and in the prestige which the latter has in the market. That is why, in addition to the provisions in paragraphs 9.1 and 9.2 above and attention to the reputational risk that could lead to the dissemination of information about the activity of the society and customers, people who are competent force is expressly a:
â€¢ Do not communicate or provide to third parties, by any means, physical or electronic, information or data of any kind about the customers. This includes individual or aggregated information.
â€¢ Failing to notify or provide to third parties, by any means, physical or electronic, information or data about the society, including as such any referral to its shareholders, operations, profitability, financial statements, contracts or agreements with partners or third parties, rights of industrial and intellectual property, etc.
â€¢ Not making statements, provide any data or give interviews to the media, or attend as a speaker at conferences, seminars and public events as a Director, officer or employee of the society, except authorization of the monitoring body, which granted it only after consideration of the overview which, in any case, will have to adhere the public appearance.
9.4. The prohibitions in paragraph 9.3 above shall not apply when the communication of data or information to be performed in compliance with the applicable legislation, at the request of the competent judicial or administrative authorities or above in line with the strategies established by the society, all this provided whether the person responsible for making such communication in accordance with the functions you have entrusted in the field of the organization and management of the society.
10. Recommendations produced by third parties.
Society will not disseminate recommendations made by third parties, but on the assumption that clients intend to do so, may inform the obligations which are incumbent upon them pursuant to the Royal Decree.
11. Monitoring body.
11.1. The monitoring body will be appointed by the Board of Directors of the society, will directly depend on the same and always act under the principle of independence with respect to those areas or units that turn your activity.
11.2. The monitoring body shall for function monitoring and surveillance of their application, as well as guidelines that integrate internal policies and procedures in its development, regularly reporting all this to the Board of Directors.
11.3. In particular, they will be functions of the monitoring body of the regulation:
â€¢ Ensure that competent people know, understand and comply with this regulation and internal policies and procedures in its development, as well as keep records up-to-date and dated such competent persons.
â€¢ Exempt competent persons from compliance with all or part of the obligations arising from this regulation, provided that there are grounds to justify it and permitted by the legislation of application.
â€¢ Interpret the rules contained in this regulation in relation to the specific applications of the same.
â€¢ In the event of incidents detected, immediately inform the Board of Directors on the same.
â€¢ Write and raise to the Board of Directors for approval an annual report on the monitoring and enforcement of this regulation and, where appropriate, of the measures taken to remedy and prevent the recurrence of deficiencies or irregularities warned.
â€¢ Where appropriate, draw up and update the list of values that you have insider and people who have access to it.
â€¢ Draw up and update a list of competent persons affected by the regulation of operations personal, indicating, where appropriate, which have delegated the management of all or part of their assets to third-party trusted entities.
â€¢ Develop and disseminate the list of values in which competent persons affected by the regulation of operations personnel may not reverse if it is not with your prior authorization and to authorize or deny such operations.
â€¢ Regularly examine the personal operations, carrying the registration thereof.
â€¢ Develop and disseminate a list of individuals belonging to each separate area.
â€¢ Oversee the existence of appropriate information barriers and detect incidents shall inform the Board of Directors.
â€¢ Maintain records that this forced for a period of six years.
â€¢ Any other call stated in this regulation.
11.4 Is obligation of competent persons meet the requirements of the monitoring body in a conscientious and accurate information and, where appropriate, provide access to information that could be held by third parties.
12. Respect of legislation and regulation.
12.1. The competent people in the society should know and respect, both in its letter and in its spirit, in addition to this regulation, the applicable legislation on the stock market, in particular that affect your specific field of activity and, in particular, chapter II of title VII of the LMV, the Royal Decree and its development provisions. The above rules will always accompany as an annex to this regulation, formed an integral part of it.
12.2 Non-compliance with this regulation and the applicable legislation may be considered very serious labour failure, irrespective of quantification of target damage that caused the failure. Also such failure will result in the obligation to indemnify society and/or its customers for any material damages that caused the failure.
12.3 Without prejudice to internal disciplinary measures that can be taken and what results of application according to the labour law, the breach of the provisions in this regulation or in the applicable legislation may give rise to the imposition of appropriate penalties.