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Managers' Transactions

Notifications concerning transactions by persons purs. to Art. 19 of the Market Abuse Regulation

Article 19 of the Market Abuse Regulation (“MAR”), which came into force on July 3, 2016, sets out new statutory regulations with regard to managers’ transactions of persons discharging managerial responsibilities at an issuer of financial instruments as well as of persons closely associated with them.

Closely associated persons are the spouse, registered partner, dependent children and any other relatives with whom the person discharging managerial responsibilities has lived in the same household for at least one year at the time of conclusion of the respective transaction, and under certain conditions legal persons, trusts or partnerships.

Under the above-mentioned Regulation, the persons concerned are obligated to notify the respective transaction upon conclusion to the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, “BaFin”) and the respective issuer.

In contrast to the previous regulation according to § 15a WpHG, once the threshold of currently EUR 5,000.00 is exceeded, only those transactions must be notified that exceed the threshold. It is not required that the transactions which were initially beneath the threshold be notified subsequently.

The template, the use of which is mandatory for all notifications, requires, i.a., that the following data be published:

  • Details of the persons discharging managerial responsibilities/persons closely associated with them
  • Reason for the notification
  • Details of the issuer
  • Details of the transaction (price, nature/volume)

Listed below are transactions for the financial years 2013 through today with shares of

adidas AG / ISIN DE000A1EWWW0:




1) Purchase was executed via a joint account held by Harm Ohlmeyer and his wife, Susanne Ohlmeyer




In 2015, adidas AG received no notifications pursuant to § 15a WpHG.


1) Purchase was executed via a joint account held by Robin Stalker and his wife, Cornelia Stalker