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A B C D E F G H I J K L M N O P R S T V W Y

AIM High

A regular update on AIM news and developments. AIM High is designed to provide useful information and advice to anyone who has an involvement with or an interest in AIM, including officers of AIM-listed companies, companies who may be considering listing on AIM, NOMADs and brokers and individuals looking for non-executive directorships.

Latest Issue

In the latest issue of AIM High we look at the current state of the IPO market and how ambitious companies considering an IPO can take a range of actions now to prepare themselves. We also look at the benefits of board diversity, the recent FPC Corporate Reporting Annual Review and our regular look at AIM market statistics. Finally, our tax expert Mark Whiteside, outlines the key tax changes for businesses that were announced in the Autumn Statement, which you can read here.

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Damned Lies and Statistics Special: 2015 Review

Wednesday 17th February 2016

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AIM Update

AIM did not have a vintage year in 2015, its twentieth anniversary year, but there were some highlights, including the amount of money raised on the market (particularly by way of secondary issues). Below is a summary of some of the more eye-catching statistics from 2015.

IPOs

The amount of money raised on AIM IPOs in 2015 (£1.158 billion) fell significantly from 2014 (just under £2.6 billion), although 2014 was the standout year in this regard since the economic crisis hit in 2008. Indeed, 2015 still remains the fourth most productive year in terms of money raised on AIM IPOs since 2007, despite having fewer admissions than each year in that period other than 2009. Whilst there were not any AIM IPOs in 2015 as notable, in terms of amount raised, as some of those in 2014, there is evidence of a trend towards amounts raised on an AIM IPO increasing above the historic average.

In terms of sector spread, the financial sector accounted for over a quarter (17) of the 61 IPOs during 2015, but it was in the healthcare sector that the largest amount (just over £390 million) was raised. Other notably active sectors were industrials and consumer services.

The year ended with a total number of 1,044 companies on AIM, a fall of 60 from 2014 and in fact the lowest year-end figure since 2004. Many have pointed to the general election as the main reason behind the slow start to 2015 in terms of IPOs, and overall global financial markets (particularly since the summer) have of course been extremely unsteady, which may well explain in part the relative low numbers for the post-election period. 2016 has not started on a much surer footing; it will be interesting to see if there is an increase in IPO activity once the financial markets begin to stabilise.

Secondary Issues

This is the area in which AIM has been most successful in 2015, as more (just over £4.3 billion) was raised by way of secondary issue than in any year since 2010, and indeed the increase from 2014 was over 30%.

Again it was healthcare where the most money (just over £2 billion) was raised, with financials (£1.134 billion) the only other sector to raise more than £1 billion by way of secondary issue.

It is clear that AIM continues to provide a good platform for companies seeking funds for continued growth.

Market Capitalisation

The number of companies on AIM, as at the end of 2015, with a market capitalisation of £1 billion or more had increased to four (from three in 2014). Those four companies, Asos, New Europe Property Investments, Hutchinson China Meditech and Abcam, represent over 11% of AIM’s total value as at the end of the year.

Of note is that it remains the case that, as at the end of the two previous years, over half of AIM companies had a market capitalisation of less than £25 million, and just over 68% had a market capitalisation of less than £50 million.

Liquidity

There were more AIM shares traded in 2015 than in any other year since AIM was launched, even though there are far fewer companies listed on AIM than there were during the pre-recession years. That said, the value of those trades (£30.885 billion) was significantly down from 2014 (£42.861 billion). Whilst the total number of trades was smaller in 2015 than in 2014, at over 5.73 million trades 2015 was the second most liquid year of AIM in its history.

Liquidity therefore remains seemingly strong in AIM shares, which is an important point for companies considering joining the market, even if the value of the shares being traded has fallen.

If you would like to discuss any AIM matters please contact either:


Andrew Millar

Partner, Corporate
Tel: 0161 836 8965
Email: andrew.millar@brabners.com

 


New Prospectus Regulation - significant changes proposed with more relaxed rules

Thursday 3rd December 2015

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AIM High - Stop Press - Issue 11

Following a review and consultation process the European Commission, on 30 November 2015, published a proposal for a new Prospectus Regulation, which when implemented would mean significant changes to when a prospectus is required, the content of a prospectus and the process for issuing a prospectus.

The changes are not imminent. There is still a legislative process to go through and the new legislation will not apply for 12 months after it is published in its final form. However, some companies may decide to place fund-raises on hold so that they can take advantage of the more relaxed rules.

We expect that the changes will require amendment to the AIM Rules in due course.

Some of the main changes contemplated by the new Prospectus Regulation are summarised below.

When a prospectus is required

  • The current member state discretion, which allows member states to prescribe a minimum fund-raise threshold of up to EUR 5 million before a prospectus is required, is to be extended up to a threshold of EUR 10 million. As is the case now, the amount is calculated over a period of 12 months and it seems inevitable that different thresholds will apply in different member states.
     
  • It remains to be seen to what extent the UK government intends to exercise this discretion, if at all. At present the UK’s threshold is the maximum EUR 5 million, and many will hope that the UK threshold will increase to EUR 10 million.
     
  • Currently a prospectus is not required for a secondary issue where the shares on offer represent less than 10% of the shares already listed on the same market. It is proposed to raise the 10% limit to 20%. Note that this is not relevant to AIM companies, as the relevant rules only apply to “regulated” markets (and AIM is not a “regulated” market for these purposes).
     
  • The rule requiring a prospectus where a takeover offer is made by way of an offer of shares in the bidder is to be relaxed – a prospectus will not be required if there is a document available describing the transaction and its impact on the bidder. The current rule requires that other document to be “equivalent” to a prospectus, which in practice means that a process to test that standard has to be undertaken.

Contents of a prospectus

  • A number of changes relate to “SMEs” – the definition of “SME” is changing from a company with a market capitalisation of EUR 100 million or more to EUR 200 million or more.

  • There is to be a reduced level of disclosure required where the issuer of a prospectus has been listed on a regulated market, or growth market, for 18 months or more.

  • SMEs not listed on a regulated market (therefore including any AIM company with a market capitalisation of EUR 200 million or less) will be able to take advantage of a further reduced disclosure regime. The detail of this will follow in subsequent legislation.

  • SMEs will also be able to choose to use a “question and answer” form of disclosure document within a prospectus (again the detail is to follow in subsequent legislation).

  • Prospectuses are to include shorter (maximum of 6 A4 pages, down from 15) summary sections, themselves split into three sections: key information on the issuing company, the security being offered, and the offer/admission.

  • Risk factors are only to be included in a prospectus if they are material and specific to the issuer and its securities. Risk factors are to be allocated across two or three categories on materiality grounds.

  • More information is to be capable of inclusion in a prospectus by reference, subject to certain requirements, including the fact that it is published electronically.

Process

  • The new Prospectus Regulation introduces a new “universal registration document”. This will allow companies that are regularly required to issue a prospectus to file (annually) a complete registration document containing certain prescribed information. They will then be able to take advantage of a streamlined (5 business days or less) process each time a prospectus is required. In practice there are unlikely to be many, if any, AIM companies that would issue a prospectus often enough to justify the expense of preparing a universal registration document.

  • There is to be free online access to any prospectus approved in the EEA via a central database. Changes are also being made to publication requirements applying to issuing companies.

Reaction to the proposed changes has, to date, been generally positive, as the costs of preparing a prospectus can, for many companies (especially those at the smaller end of the scale), be prohibitive. Some commentators and pressure groups have even encouraged the reforms to go further, although acknowledging that the reforms under the new Prospectus Regulation are to be welcomed as a step in the right direction.

If you would like to discuss further how the changes may impact on you, please contact either:


Andrew Millar
Partner, Corporate
Tel: 0161 836 8965
Email: andrew.millar@brabners.com

 



Mark Morell
Associate, Corporate
Tel: 0161 836 8931
Email: mark.morrell@brabners.com


AIM awaits Enterprise Investment Scheme changes

Monday 16th November 2015

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AIM High - Issue 10 

Changes to the rules for the Enterprise Investment Scheme (EIS) and Venture Capital Trusts (VCT) are expected to be finalised in November.

In March, George Osborne lowered the annual cap for money raised under the VCT or EIS schemes, which offer generous tax breaks for investing in higher-risk smaller companies, to £15m. In July the Chancellor proposed this limit be further reduced to £12m. When implemented, the new rules will make it more difficult for some AIM-quoted companies to raise additional investment. Recent fundraisings could be affected (and some companies may have already lost out on investment) as the rules are expected to be backdated to April 2015, so anybody who has raised money via EIS since 6 April could fall foul of the new rules and HMRC may claw back the tax relief.

New qualifying criteria for EIS and VCT, including the reduced annual cap, are proposed. The revised criteria include the provision that a company raising cash can only take advantage of EIS or VCT within seven years of its first commercial sale.

A distinction is being made for knowledge intensive companies. These are companies that spent at least 15% of their operating costs on R&D in one of the previous three years, or 10% a year for each of those three years, and are creating intellectual property. For these companies the time limit for taking advantage of EIS or VCT is 10 years from the first sale, they can have up to 500 employees (as opposed to 249), and the investment cap is £20m.

It remains to be seen how much the changes, when implemented, impact on AIM companies and whether there is a decline in both numbers of and size of future fundraisings. 

If you would like more information on these changes please contact either: 


Andrew Millar

Partner, Corporate 
Tel: 0161 836 8965
Email Andrew

 


Mark Morell
 

Associate, Corporate 
Tel: 0161 836 8931
Email Mark


Inside AIM: Disclosures relating to equity financing products

Monday 16th November 2015

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AIM High - Issue 10

AIM has retained the new format of Inside AIM (ad hoc notices as opposed to a periodic stand-alone publication), and recently issued updates regarding AIM company disclosures arising from equity financing products and the new Market Abuse Regulations (“MAR”). The full text of the notices can be found here, which is also where historic Inside AIM publications and notices are located.

The notice regarding disclosures relates only to such products that involve AIM-traded securities and “in which AIM companies or their directors may have an interest”. Examples given include convertible loans and crowd funding type products aimed at non-institutional investors.

Key points from the notice include:

  • AIM has already required correction of inaccurate disclosures regarding such products (the message being that it will do so again).
     
  • Companies should consider, with their Nomads, the terms (and particularly non-standard terms) of such products to ensure that sufficient information is given to the market, bearing in mind the general disclosure obligations under Rules 10 and 11 of the AIM Rules.
     
  • Disclosures regarding equity financing products should be careful to use the correct terminology to ensure appropriate and sufficient disclosure.
     
  • Appropriate updates should be given to the market, where necessary, after the initial disclosure has been made as part of the company’s ongoing disclosure obligations.
     
  • Where arrangements involve directors’ interests in AIM company shares, the broad definition of “deal” in the AIM Rules will need careful consideration to ensure that details are clearly and fully disclosed. This is a reminder that it is not just “normal” share transfers that are caught by the restriction on deals by certain individuals during an AIM company’s close periods.
     
  • A company should ensure that it has appropriate arrangements in place with its directors to enable the company to obtain all necessary information to comply with its director dealing notification requirements.
     
  • Any disclosures to be made in respect of equity financing products should be prepared by someone who is independent – a director should not, for example, prepare the disclosure to be made in respect of a product that has been made available to him/her.
     
  • Companies should consult with their Nomads “at the earliest opportunity about proper disclosure”, and Nomads should consult with AIM itself regarding any doubt as to the disclosure requirements.

The MAR update highlights the future disclosure regime for AIM companies. The MAR will come into force on 3 June 2016 and will apply to AIM companies.

The AIM Regulation team at the London Stock Exchange (LSE) considers that, for the integrity of AIM and the maintenance of an orderly market, it is appropriate to retain the disclosure provisions in AIM Rule 11 even following the implementation of the MAR. The key disclosure obligations of the MAR relate to the disclosure of inside information and disclosure of deals by persons discharging managerial responsibilities and closely associated persons.

The Financial Consent Authority (FCA) will be the competent authority under the MAR, meaning that AIM companies will therefore owe obligations both to the FCA under the MAR and to the LSE under the AIM Rules.

AIM Regulation intends to work closely with the FCA to minimise duplication. In relation to real-time disclosure, for example, AIM Regulation envisages that it will continue to discuss announcement obligations with Nomads in the first instance and will co-ordinate with the FCA as necessary. However, AIM Regulation acknowledges that only the FCA will be able to opine on MAR compliance and will retain the right to engage directly with AIM companies.

AIM Regulation will undertake a consultation if changes to the AIM Rules are necessary.

For more information on disclosures relating to equity financing products please contact either: 


Andrew Millar

Partner, Corporate 
Tel: 0161 836 8965
Email Andrew

 



Mark Morell
 

Associate, Corporate 
Tel: 0161 836 8931
Email Mark


Consultation on changes to AIM Rules for Companies

Monday 16th November 2015

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AIM High - Issue 10

The London Stock Exchange (LSE) AIM Notice 42 is consulting on proposed changes to the AIM Rules for Companies which apply to investing companies and to AIM companies that undertake a fundamental change of business.

The LSE proposes to amend AIM Rule 8 (investing companies) to increase the amount in cash that an applicant seeking admission as an investing company must raise via an equity fundraising on, or immediately before, admission from £3 million to £6 million.

The principal changes to AIM Rule 15 (fundamental changes of business) proposed by the LSE are summarised below.

  • An AIM company that becomes a cash shell following a fundamental disposal will be regarded as an AIM Rule 15 cash shell (rather than being automatically treated as an investing company). A new definition of “AIM Rule 15 cash shell” would be added to the Glossary terms.
     
  • Within six months of becoming an AIM Rule 15 cash shell, the AIM company must make an acquisition or acquisitions which constitute a reverse takeover under AIM Rule 14. For the purposes of this rule only, becoming an investing company pursuant to AIM Rule 8 (including the associated raising of funds as specified in AIM Rule 8) will be treated as a reverse takeover and the provisions of AIM Rule 14 will apply, including the requirement to publish an admission document.
     
  • An AIM Rule 15 cash shell that has not completed a reverse takeover as required, will have trading in its AIM securities suspended by the LSE.
     
  • Where an AIM company became an investing company prior to the date on which the new rules come into effect, the requirements of AIM Rule 15 set out in the AIM Rules for Companies (May 2014) will continue to apply.

The LSE also proposes to include some new guidance in the Guidance Notes on AIM Rule 15. Notably, the AIM company should consult the LSE as soon as possible where there is any question as to (a) whether it has become an AIM Rule 15 cash shell, or (b) the point at which it becomes an Aim Rule 15 cash shell.

Additionally, where an AIM Rule 15 cash shell does not intend or wish to undertake a reverse takeover in accordance with AIM Rule 15, the LSE expects it to obtain shareholder approval to cancel its admission to AIM in accordance with AIM Rule 41, and to consider how best to return any remaining funds to shareholders.

The deadline for responses was on 12 November; we await the outcome of the consultation.

If you would like more information on the changes to AIM Rules for Companies please contact either:


Andrew Millar

Partner, Corporate 
Tel: 0161 836 8965
Email Andrew

 



Mark Morell

Associate, Corporate 
Tel: 0161 836 8931
Email Mark


New Panel Practice Statements and Response Statements

Monday 16th November 2015

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AIM High - Issue 10 

The much trailed mega-brew merger between AB InBev and SAB Miller means that takeovers are highly topical at the moment, but to less fanfare and publicity the Takeover Panel Executive recently published Practice Statement No. 29 and Practice Statement No. 30 on 8 October 2015 (withdrawing Practice Statement No. 27 and Practice Statement No. 23). 

Practice Statement No. 29

Practice Statement No. 29 provides guidance on the Takeover Panel Executive’s interpretation and application of Rule 21.2 (offer-related arrangements).

Rule 21.2(a) of the Takeover Code provides that, except with Panel consent, neither the offeree nor any person acting in concert with it may enter into an offer-related arrangement with either the offeror or any person acting in concert with it during an offer period or when an offer is reasonably in contemplation. Rule 21.2(b) defines an “offer-related arrangement” as being any agreement, arrangement or commitment in connection with an offer, including any inducement fee arrangement or other arrangement having a similar or comparable financial or economic effect. Certain agreements and commitments, which are listed in paragraphs (i) to (vii) of Rule 21.2(b), are excluded from this prohibition. 

The Executive’s guidance is focused on its interpretation and application of Rule 21.2 in relation to:

(a)  certain exclusions to the prohibition on offer-related arrangements provided in paragraphs (i) to (vii) of Rule 21.2(b);

(b)  agreements between an offeror and the offeree company relating to the conduct, implementation and/or terms of an offer (Bid Conduct Agreements); and

(c)  agreements under which an offeree company may agree to pay an inducement fee to an offeror in the limited circumstances set out in Notes 1 and 2 on Rule 21.2. 

This practice statement is a reminder that the market, and indeed the Takeover Panel Executive, is alive to offer-related arrangements and attempts to circumvent the rules relating to them.

Practice Statement No. 30

Practice Statement No. 30 sets out how the Takeover Panel Executive considers parties to an offer may comply with the requirements of Rule 20.2 (relating to the equality of information to competing bidders) where commercially sensitive information is supplied to lawyers or economists advising an offeror on an “outside counsel only” basis for the purposes of enabling them to consider the need for and, where necessary, to obtain the consent of a competition authority or other regulatory body where there is a competing offeror. However, if the terms of the restricted information are provided to, or accessed or deduced by, an offeror the terms of Rule 20.2 would then be normally applied to such information. 

Response Statements

On 23 October 2015 the Code Committee published response statements 2015/1-3 in respect of previous consultations on dividends, the definition of voting rights and the definition of acting in concert, respectively.

The Code Committee has adopted the amendments to the Takeover Code in relation to the definition of acting in concert in substantively the same form consulted on. The amendments to the Takeover Code relating to the definition of voting rights include minor chnages from the consultation to provide that where shares in a company are held by, or on behalf of, the company itself, or by a subsidiary, and the voting rights in respect of those shares are not exercisable by virtue of the operation of applicable legislation, those shares will be treated as if they were treasury shares. 

The adoption of amendments to the Takeover Code relating to dividends shows greater changes from the consultation. The effect of the changes is to require an offeror, in each statement made under Rule 2.5(a)(i), firm offer announcement and offer document, to state that the offeror will have the right to reduce the offer consideration by the amount of any dividend (or other distribution) which is paid or becomes payable by the offeree company to offeree company shareholders, unless, and to the extent that, the offeror expressly states that offeree company shareholders will be entitled to receive all or part of a specified dividend in addition to the offer consideration.

Each of the amendments to the Takeover Code will take effect and revised pages of the Takeover Code will be published on 23 November 2015.

For further details about the guidance and the new Practice Statements, or the amendments to the Takeover Code, or to discuss any other Takeover Code related concern or question, please contact:


Andrew Millar

Partner, Corporate
Tel: 0161 836 8965
Email Andrew

 

 


Damned lies and statistics: Why AIM company management ignore retail investors at their peril

Monday 16th November 2015

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AIM High - Issue 10

In this edition’s version of damned lies and statistics we are indebted to Hardman & Co for allowing us to use one of their research notes, which highlights the importance of retail investors to all quoted companies and, in particular, those traded on AIM.

To read the full research please click here.

In summary, information published by the Office for National Statistics shows that retail investors form the largest cohort of investors in AIM, constituting 30.9%. AIM management teams ignore these investors at their peril. 

If you would like more information on the research published by Hardman & Co or for to discuss any AIM issues please contact either:


Andrew Millar

Partner, Corporate 
Tel: 0161 836 8965
Email Andrew

 



Mark Morell

Associate, Corporate 
Tel: 0161 836 8931
Email Mark

 


Inside AIM: Consideration of free float and update on systems, procedures and controls

Tuesday 4th August 2015

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AIM High - Issue 9

AIM Regulation’s consolidated newsletter “Inside AIM”, which provides technical guidance, is being replaced with individual updates on AIM’s website. It has recently published two articles under Inside AIM in the revised format.

Consideration of free float

The first update deals with a company’s free float (being the number of shares made available to new shareholders on an IPO).

Even though the AIM Rules do not prescribe a minimum level of free float, AIM Regulation considers it an important factor which the nominated adviser (“Nomad”) should consider when bringing an applicant to the market. The guidance notes that a sufficient free float is fundamental to the orderly trading and liquidity of the securities once admitted to AIM, which is inextricably linked to the company’s appropriateness to be admitted to AIM.

The guidance is important for both prospective AIM companies and their Nomads, as it highlights some factors that the LSE will often discuss with Nomads bringing new companies to the market.

  • How the securities are likely to trade once admitted, including the spread and nature of the shareholders comprising the free float.
     
  • Failure to raise initial target funds may be indicative of more fundamental issues of appropriateness and is a matter which should be explored by the Nomad.
     
  • Limited free float should give rise to questions concerning the rationale for the applicant to seek admission.
     
  • Where there are concentrated shareholdings e.g. due to family connections etc, undue influence, control and ongoing corporate governance arrangements should be considered in conjunction with the free float issue.

Systems, procedures and controls – financial policies and procedures

The second update relates to the systems, procedures and controls that a company must have in place to comply with AIM Rule 31, which prescribes an AIM company’s, and its directors’, responsibility for compliance with the AIM Rules. 

AIM Regulation has stressed that this is an assessment which should take place prior to admission, and that Nomads should undertake a meaningful review of the financial policies and procedure documents prepared by the issuer, in conjunction with its reporting accountants, and assess whether those polices are capable of working in practice.

If you would like more information on these updates please contact either:


Andrew Millar

Partner, Corporate
Tel: 0161 836 8965
Email: andrew.millar@brabners.com

 


Shareholder Voting Working Group discussion paper on transparency

Tuesday 4th August 2015

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AIM High - Issue 9

The Shareholder Voting Working Group (SVWG) published a discussion paper on proxy voting and improving transparency on 1 July 2015. The paper describes barriers to trust and transparency in proxy voting and suggests possible solutions.

AIM companies should be aware of the proposals in the paper, as well as the 30 September deadline by which comments are invited. In particular the suggestion that all issuers with CREST member shareholders should make CREST voting available is something about which all AIM companies should take note. Other best practice proposals focus on the role of others in the voting chain, and include:

  • Registrars should agree a standard approach to dealing with split over voted accounts.
     
  •  Investors should publicly disclose their voting record/votes submitted on a regular basis (for example, annually) and, separately, notify issuers of their voting intentions when not voting in accordance with management recommendations, specifically with enough time to allow issuers to engage on the matter before the meeting.
     
  • Amendment of the law on record dates to minimise the impact of stock lending, the suggestion being that voting cut-off dates and dividend record dates are kept separate by at least five days.

The SVWG notes that it has looked at ways of making improvements to existing processes rather than attempting to change the underlying systems. It states that a new standalone electronic voting system would be costly and likely to be out of date before implementation.

If you would like more information or wish to provide your comments on the proposals please contact either:


Andrew Millar

Partner, Corporate
Tel: 0161 836 8965
Email: andrew.millar@brabners.com

 


The CityUK report on European listings regimes and unlocking growth

Tuesday 4th August 2015

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AIM High - Issue 9

The CityUK recently published the findings of its review of the European listings regime, which was carried out in response to a government invitation announced as part of the March 2015 Budget. The review aligns with the European Commission’s commitment to develop a Capital Markets Union (CMU) and makes proposals on how the current regime could be improved to advance the goals of a CMU. It also makes recommendations on improving the regime for new listings and examines the continuing obligations of listed issuers, which are also relevant to the CMU goals of making capital markets well-regulated and appropriately accessible.

The report considers that capital markets currently play too small a role in financing growth, and that European businesses, particularly in the SME sector, remain heavily reliant on banks. Its recommendations are aimed at making Europe’s capital markets more accessible and fundraising quicker and cheaper, with a view to ensuring that companies of all sizes and levels of maturity are able to secure capital for long-term growth from more diverse sources. Key recommendations include:

  • Increasing the awareness of capital markets options available to SMEs by, among other things, creating national registers and a central European register of capital markets.
     
  • Minimising the regulatory complexity of raising capital and listing on an unregulated market with a view to managing costs.
     
  • Within the IPO process, making information available sooner to investors, including publishing the prospectus earlier in the process.
     
  • Improving the quality of information made available to investors by making the prospectus more focused and relevant.
     
  • Increasing investor confidence in pan-European offerings by harmonising the approach of National Competent Authorities to prospectus review and approval, and by introducing minimum corporate governance requirements.
     
  • Reducing the prospectus disclosure requirements for follow on issuances, in particular heavily reducing the specific disclosures required under the annexures to the Prospectus Regulation, and eliminating the need to repeat information available on a dedicated section of the issuer’s website.

It is hoped that making equity funding easier to access will drive increased activity in the pre-IPO and the IPO markets. This can only be good for AIM, as one of the established European growth markets, and positive for the companies that are already trading or considering an IPO if it becomes easier to invest in equities and leads to an increase in the capital available.

If you would like more information on the report for to discuss any AIM issues please contact either:


Andrew Millar

Partner, Corporate
Tel: 0161 836 8965
Email: andrew.millar@brabners.com

 


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