GC100: Guidelines on the practical implementation of certain aspects of the Listing Rules and the Disclosure Rules | Practical Law

GC100: Guidelines on the practical implementation of certain aspects of the Listing Rules and the Disclosure Rules | Practical Law

Please note that these guidelines have now been superseded by a new set of guidelines published in May 2012. For links to the updated guidelines, see Listing Rules: GC100 guidelines updated and republished.

GC100: Guidelines on the practical implementation of certain aspects of the Listing Rules and the Disclosure Rules

by Practical Law
Published on 01 Jun 2007 • United Kingdom
Please note that these guidelines have now been superseded by a new set of guidelines published in May 2012. For links to the updated guidelines, see Listing Rules: GC100 guidelines updated and republished.
The Association of General Counsel and Company Secretaries of the FTSE 100 (GC100) has published its revised set of guidelines to assist members of GC100 in: (1) establishing procedures, systems and controls to ensure compliance with obligations under the Listing Rules and the Disclosure and Transparency Rules); (2) complying with the requirement under the Disclosure Rules to maintain Insider Lists; and (3) implementing procedures to enable compliance with the requirements under the Disclosure Rules for directors and other senior executives to disclose dealings in the company's securities and the requirements of the Listing Rules that dealings must be restricted in accordance with the Model Code. The guidelines replace the initial set of guidelines circulated to members of GC100 two years ago.

GC100 Guidelines: practical implementation of certain aspects of the Listing Rules and the Disclosure Rules

These Guidelines have been drawn up by the GC100 Listing Rules Working Group led by Peter Maynard, Group Legal Services Director at Prudential plc and Rosemary Martin company secretary and general counsel at Reuters.
The GC100 wishes to express many thanks to all those GC100 member companies who contributed to these Guidelines particularly all those who participated in the Listing Rules Working Group. Particular thanks go to William Underhill at Slaughter and May. Many thanks also to Vanessa Knapp at Freshfields Bruckhaus Deringer and James Palmer, Caroline Goodall and Stephanie Maguire at Herbert Smith.
The Guidelines are divided into three sections:
  • Part I: Guidelines for establishing procedures, systems and controls to ensure compliance with the Listing Rules.
  • Part II: Guidelines on the requirement to maintain Insider Lists.
  • Part III: Guidelines on obligations to notify dealings and model code compliance.
The version in black has been seen by the FSA which has agreed to add the following wording: "The FSA has seen this material in draft and recognises these Guidelines as a useful contribution to a difficult area."
The blue mark-up reflects recent changes in the law which have been added to the Guidelines by the PLC Corporate service. These have not been seen by the FSA.