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Adrian Rycerski
ORCID: 0000-0002-4673-0450

PhD Candidate at the Chair of European Law at the Faculty of Law and Administration of Adam Mickiewicz University in Poznań. Certified Alternative Trading System Advisor (Certificate 18/2015). He has worked on the implementation of a number of EU regulations, including MAR, MiFID II, PRIIP, PSD2, as well as PFSA and ESMA recommendations, assisting public companies, banks and investment firms.

 
DOI: 10.33226/0137-5490.2020.6.2

The article presents the issue of maintaining the insider list referred to in Article 18 MAR in the capital group. The main research problem analysed by the authors is whether the provisions MAR constitute the legal basis for including the employees of the issuer's subsidiaries in the insider list maintained by the issuer (the parent company). In the authors' opinion, employees of subsidiaries having preferential access to inside information produced in a subsidiary should be considered as persons to be included in the insider list maintained by the issuer. The proposed interpretation is consistent with all views treating the capital group as a single economic unit, pursuing an interest that is essentially convergent for all participants of the group.

Keywords: insider list; inside information; MAR; market abuse; issuer; capital group