THE RECEIPT OF INSIDE INFORMATION BY Pello CAPITAL IS SUBJECT TO THE FOLLOWING STRICT CONDITIONS:
Pello Capital may receive market soundings.
Inside information disclosed may only be conveyed to Pello Capital 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.
Pello Capital 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 Pello are recorded by the disclosing market participant in compliance with the Market Abuse Regulation. Market soundings may only be conducted via telephone to Pello Capital during normal office hours of 9am -5pm.
Pello Capital 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 Pello’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 Pello Capital 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 Pello Capital having agreed to be made an insider, we would also expect the disclosing market participant to again contact Pello Capital once any inside information conveyed to us ceases to be inside information.
The below individuals are the designated “Gatekeeper” for market soundings for Pello and all other individuals within Pello Capital have been advised that they are not permitted to receive market soundings. The “Gatekeepers” co-ordinate all requests relating to the receipt of market soundings and the cleansing of inside information, therefore please only contact the following “Gatekeeper” individuals:
Gatekeeper contact details:
|Nick Josh||Head of Stockbroking||020 3700 firstname.lastname@example.org|
|Dan Gee||CEO||020 3700 email@example.com|
|Callum Hill||Stock Broker||020 3700 firstname.lastname@example.org|
|Apeksha Tanna||Analyst||020 3700 email@example.com|