Market Soundings

THE RECEIPT OF INSIDE INFORMATION BY SCH ADVISORS IS SUBJECT TO THE FOLLOWING STRICT CONDITIONS:

SCH Advisors may receive market soundings.

Inside information disclosed may only be conveyed to SCH Advisors if it is being carried out during the normal course of the exercise of employment, profession or duties in compliance with the Market Abuse Regulation.

SCH Advisors will only accept market soundings from an authorised person from legitimate sources.

If contact is made via telephone:
We expect that such calls made to SCH are recorded by the disclosing market participant in compliance with the Market Abuse Regulation. Market soundings may only be conducted via telephone to SCH Advisors during normal office hours of 9am -5pm.

SCH Advisors reserves the right to record the telephone lines of any individual who is likely to receive inside information for training and quality assurance purposes during the course of a market sounding. This is not limited to the “Gatekeepers” outlined below and will be at SCH’s discretion.

If contact is made via email:
We expect that these should be appropriately subject headed and in accordance with the criteria stated under the relevant Market Abuse Regulations.

If contact is made in person:
Then we will expect an email as soon as possible setting out the date and time, attendees of the meeting and the details of the sounding that was discussed. This would need to be agreed by SCH Advisors as being accurate. Such agreement by both parties should be within 5 workings days as specified within the Market Abuse Regulations.

Agreement to be made “Inside”
Subject to SCH Advisors having agreed to be made an insider, we would also expect the disclosing market participant to again contact SCH Advisors once any inside information conveyed to us ceases to be inside information.