Management transactions

Last modified: 27.5.2021

Managers’ transactions

Each manager must notify Optomed and the FIN-FSA of every transaction in the financial instruments of the company conducted on his/her own account.1 The notifications shall be made promptly and no later than three business days after the date of the transaction (T+3).

In light of Optomed’s obligation to publish such information, managers must submit an informal notice to Optomed ( and on the date of the transaction and that the actual notification is made to Optomed at the latest within two business days after the date of the transaction (T+2).

The notification shall be sent in electronic format to Optomed’s insider administration ( and and to the FIN-FSA (by sending a secure email at the web page to the address by using the form approved by the FIN-FSA, which is available at the FIN-FSA’s website (Related Document G) and include the information specified therein. The company’s insider administration may be contacted for further information.

If a manager authorises another person (e.g. an asset manager) to make the notifications on its behalf, information thereof (and the contact details of the relevant authorised persons) shall be submitted to the insider administration in writing. Such authorisation does not relieve the relevant manager from his/her liability.

1 Under MAR, a person’s obligation to notify transactions applies in respect of the relevant person, once a total amount of EUR 5,000 has been reached within a calendar year (the threshold is calculated by adding without netting all transactions conducted within a certain calendar year).However, Optomed recommends that all transactions are notified (also below the threshold). Optomed also intends to publish all transactions notified to Optomed (whether or not the 5,000 euro limit has been reached).