Background

Rule 8 of the UK Takeover Code (the โ€œCodeโ€) sets out the circumstances in which Dealing Disclosures and/or Opening Position Disclosures are required to be made by:

  • The parties to an offer;
  • Persons acting in concert with the parties to an offer;
  • Persons with an interest in relevant securities of 1% or more; and
  • Exempt principal traders (โ€œEPTsโ€) connected with the parties to an offer.

Here we are concerned with persons with an interest in relevant securities of 1% or more.

There are requirements for:

  • Opening Position Disclosures; and
  • Dealing Disclosures.