The issuer must keep a list of all PDMRs and PCAs (i.e. regardless of the logbook). There is no requirement for special format for the list. The list must state: (a) name (and appropriate position) of PDMRs and (b) names and business names regarding their PCAs in a way that makes it possible to derive who is associated to who. It is not the responsibility of the issuer to check who is associated or if such person has been notified. Nor does the issuer have to do anything with the transaction notifications received by the issuer. The list is not public.

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