Les pre-close calls se hold before the period or from blackout, preceding the publication of annual or interim resultss. Remember that for this period, listed companies must avoid communicate froms information additional or from updates and in particular exchanges with analysts.

This practice, which developed among Europe's largest capitalizations, allows in particular to steer the market consensus and enable analysts to adjust their forecasts for future figures and fine-tune their recommendations for the Group.s titles.

Un risk from unlawful disclosure of privileged information

Dn its May 29, 2024 press release, Esma considers that this practice presents an inherent risk of transmission insider information. It should be remembered that the illicit disclosure of privileged information is a criminal offence. prohibited by the Market Abuse Regulation of April 16, 2014 (known as the MAR Regulation). and pre-close calls do not benefit from any exemption.

In this respect, Esma indicates that recently observed a number of episodes of high price volatility shortly after pre-close calls. This situation generates many of suspicion with regard to any unlawful disclosure of privileged information. The press so reported unusually volatile share prices for companies such as Puma, Porsche, Carrefour, Adidas and Siemens.

Faced with this situation, Esma list in its press release various good practices implemented by some listed companies for frame their pre-close calls. Lobjectif is to prevent in concrete terms disclosure of insider information during paddockse calls.

Best practices for pre-close calls

Firstly, ds part of the preparation ofes pre-close calls, the listed company devrait procéfromr à a in-depth assessment information it intends to disclose to make sure absence insider informations.

Secondly, en terms oforganization, les pre-close calls must respectsr the principle of transparency andequality access toinvestor information :

The listed company can publish the calendar in advance from pre-close calls he intends visit, specifying in particular the date, the place, land larticipants for discussion.

The listed company can also simultaneously available on sound website visit documents used during pre-close calls. Finally, the listed company can hold a register information disclosed during the pre-close calls and publish it on its website.

Thirdly, to for evidentiary purposes, les pre-close calls can be recorded for justify information actually transmitted. In case of need, these recordingss can then be put available from market authorities at their request.

Sif insider information is nevertheless disclosed, lESMA reminds that the listed company must restore equality of information between investors by making this information public.

L'approach to Autorité des marchés financiers ("AMF ")

If the'AMF has never expressly pronounced on the subject ofes pre-close calls, it has taken a position on the meetings presentation of financial results. The lAMF about them is moreover similar to that of Esma for pre-close calls.

THE AMF recommends so that documents provided, at these presentation meetings, do include no additional information that is significant or different from that provided to the public when the results are published. She also recalls that these documents must be systematically put online without delay at the latest at the start of meetings.

Remember that lack of implementation of these good practices nis not punishable as such. Nevertheless, she will be without a doubt takene into account by the AMF, or by the competent authorities from other European Union countries, during a survey andif applicable, a sanction procedure for disclosure of insider information.