Some firms may have been in receipt of a ‘Dear Compliance Officer’ letter reminding them of the ‘cold-shouldering’ imposed by the Takeover Panel on three individuals.
The concept of cold-shouldering arises from 1(b)(v) of the Introduction to Takeover Code(‘Code’) when a Panel Statement is made to the effect that an individual or individuals are not likely to comply with the Code. By virtue of MAR 4.3 authorised firms must not act, or continue to act, for such persons in connection with a transaction to which the Code applies. The letter advises that firms should remind all approved persons at their firm about the cold-shouldering of the three individuals. The Panel Statement remains in place for three years from 30 April 2010.