Dear Sirs (the "Company") I am writing to all football clubs that have securities listed on the UK Listing Authority's Official List ("listed football clubs"). The UK Listing Authority recognises that at certain times of the year, particularly during open transfer windows, the likelihood of price sensitive developments increases, as does press speculation in relation to such developments. An example of a price sensitive development might be a transfer deal with short or long term financial consequences that are material to a club's prospects.
It is therefore important for listed football clubs to take measures that ensure they remain in compliance with their obligations under the UK Listing Authority's Listing Rules (the "Listing Rules"). We therefore remind you of the following:
- the Company must release any price sensitive information, without delay, over a Regulatory Information Service before it is released elsewhere (see paragraphs 9.1, 9.2 and 9.6 of the Listing Rules);
- the Company should prepare for the leak of any price sensitive developments. We would suggest that where such a development is being kept confidential, under paragraph 9.4 of the Listing Rules, that a holding announcement is prepared. In the event of a leak of the price sensitive development the holding announcement can then be released immediately through a Regulatory Information Service;
- the Company should advise any third parties involved in negotiations of the Company's disclosure obligations under the Listing Rules ; and
- we would refer the Company to Chapter 15 of the UKLA's guidance on the dissemination of price sensitive information, "The PSI Guide", which is found in Appendix 2 of the UKLA Guidance Manual.
I would also like to take this opportunity to remind you that sanctions for failure to comply with the Listing Rules include public censures and unlimited fines.
The Listing Rules and UKLA Guidance Manual are available on www.fsa.gov.uk/ukla.
Background
- The nine football clubs with securities on the UKLA Official List are: Aston Villa; Celtic; Leeds United; Manchester United; Newcastle United; Southampton; Sunderland; Tottenham Hotspur; Heart of Midlothian
- The FSA is the principal regulator of the UK financial services industry and has four objectives under the Financial Services and Markets Act 2000: maintaining market confidence; promoting public understanding of the financial system; the protection of consumers; and fighting financial crime.
- The FSA aims to maintain efficient, orderly and clean financial markets and help retail consumers achieve a fair deal.
