This precedent memorandum sets out a ‘specimen’ group-wide dealing Policy published by The Chartered Governance Institute (formerly known as ICSA: The Governance Institute) (CGI), GC100, the Quoted Companies Alliance (QCA) and other market participants. It was developed after the Financial Conduct Authority (FCA) decided to delete the Model Code (which used to form part of the listing rules) due to its incompatibility with the EU Market Abuse Regulation which came into force on 3 July 2016.

The CGI, GC 100 and the QCA agreed it would be of great benefit for listed and quoted companies to be able to turn to an equivalent version of the Model Code. Companies with a former premium listing of equity shares were previously required to comply with the Model Code, which restricted persons discharging managerial responsibilities (PDMRs) dealing in the company’s securities at certain times. It is intended that listed and AIM companies apply the group-wide dealing policy to PDMRs, their employees and their subsidiaries to give them an introduction to the concept of market abuse and to ensure that they do not