The enactment of the Investor Protection Improvement Act on October 31, 2004 and the implementation act on transparency guidelines of January 20, 2007 considerably tightened the obligations for the notification and disclosure of securities transactions of shares and financial instruments of the company for a particular group of persons (so called Directors' Dealings).
The obligations for the notification and disclosure refer to the Board of Management and Supervisory Board Members. Persons closely associated with the afore-mentioned Members of the Supervisory Board, Board of Management are also subject to the notification and disclosure requirements. The new element is that from now on legal entities, other companies or institutions in which the afore-mentioned persons, or persons closely associated with them, perform leading or controlling positions also have to declare their transactions with securities of the company.
Furthermore, transactions which exceed the amount of EUR 5,000 within any calendar year now have to be declared (previously: EUR 25,000 within 30 calendar days). The exception for transactions based on employment contracts or as a component of compensation (e.g. the sale of employee shares) is no longer available.