AIMing to support companies and nominated advisors through Covid challenges
As companies throughout the UK face the unprecedented challenges caused by the Coronavirus (COVID-19) pandemic, on 20 March it was announced that discretion will be applied to the application of certain of the AIM Rules for Companies and the AIM Rules for Nominated Advisers (AIM Rules). These are temporary measures being implemented to support both AIM companies and nominated advisers.
Details of the temporary measures are set out below. Further information can be found in the latest edition of the Inside AIM newsletter on the London Stock Exchange’s website.
- Disclosure requirements and the temporary suspension of trading
Under the AIM Rules, all AIM companies must make timely and accurate disclosures. Even during the ongoing pandemic, it remains a key requirement that all AIM companies continue to adhere to their disclosure obligations. Nomads must keep on top of what their AIM companies are doing in response to the pandemic, so that they are able to make the required disclosures.
Where circumstances caused by Coronavirus impede an AIM company’s ability to make such disclosures, meaning more time is required to make a compliant notification, the nominated adviser should approach AIM Regulation to discuss a potential temporary suspension of trading. Any suspension will be in place for a limited period sufficient to enable the AIM company to make a fully complaint notification.
- Suspended AIM companies
AIM Regulation are using their discretion to extend the period of suspension of trading which gives rise to a cancellation of a company’s AIM listing from 6 months to 12 months. This should allow AIM companies extra time to resolve any reasons for suspension.
Please note that this extension only applies to AIM companies that have been suspended between 30 September 2019 – 1 July 2020.
- Engagement responsibilities for a nominated adviser
As part of a nominated adviser’s due diligence duties, they are generally required to carry out a site visit to the AIM company’s material place of operations and meet the directors and key managers. As current travel restrictions and social distancing measures mean it is difficult for nominated advisers to carry out such visits to new clients, there will be a temporary suspension of this requirement. Nominated advisers should use alternative measures available, such as telephone and virtual meetings. This also applies to nominated advisers providing directors’ AIM Rules education.
As the situation develops, we can expect further guidance on the AIM Regulations, in particular regarding the potential impact on financial reporting and we will keep you updated on this.
For questions and further information on AIM regulation, please contact Helen Garner on 01892 506270 or at firstname.lastname@example.org.
For more guidance, and further information, visit our Coronavirus hub.