The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement
Company Related Person/Recipient of
Information from a Corporate Insider
■ Generally, a person needs to be an insider, i.e. a "company-related person"
■ A "company-related person" is:
i. any officer, agent, or employee (Officers, etc.) of a Listed Company, its Parent Company or its Subsidiary, if he/she
comes to know a material fact in the course of his/her duties;
ii.
iii.
iv.
V.
vi.
any shareholder who has a right of access to the accounting book of the Listed Company (3% or more voting rights), if
it comes to know a material fact in exercising its book inspection rights;
any person having authority pursuant to any laws and regulations over the activities of the Listed Company, if he/she
comes to know a material fact in exercising such statutory rights;
any party (or its officer or agent) who has concluded a contract with, or is in the process of concluding a contract with,
the Listed Company, if comes to know a material fact in the course of the execution, negotiation, or performance of
such agreement;
An Officer, etc. of a person listed in item ii or iv above who is a juridical person where such an Officers, etc. has come to
know a material fact in the course of his/her duty; and
any person who was a company related person in i. to v. above, but who ceased to be a company-related person less
than one year before
Morgan Lewis
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