In the current context of high market volatility, opportunity lies in the launch of buy-back programmes or in the amendment of terms of existing programmes. Low share prices could make worth increasing treasury share portfolios to service future incentive plans, extraordinary financial transactions or the distribution of scrip dividends.

However, given Covid-19’s impact on the business world, issuers must be particularly cautious when planning and carrying out buy-back programmes in order to safeguard normal market operation in accordance with recent ESMA recommendations on market disclosures and transparency.

Our in-depth analysis draws issuers’ attention to the need to adopt a policy for disclosures of price-sensitive information that are as timely as possible and based on principles of precaution. It also examines some recent CONSOB recommendations and Italian Supreme Court caselaw on market disclosures. Lastly, we offer a brief overview of some precautionary measures and safeguards that issuers can put in place.

If you would like access to the analysis produced by our Capital Markets Focus Team, in coordination with the Covid-19 Task Force, please send your request by email to covid19@belex.com.