Question 18: Application of the APM Guidelines in the context of COVID-19Paragraphs 8, 17-19, 33, 34, 41 and 43 of the APM Guidelines.

Date last updated: April 2020

Question: How should an issuer present the impact of COVID-19 for the purpose of the APM Guidelines?

Answer: ESMA acknowledges that, due tothe impacts of the COVID-19 pandemic on their operations, issuers may decide to disclose new, or to adjust, alternative performance measures in ad-hoc disclosures published in accordance with Article 17 of MAR, in management reportsor additional periodic financial information published in accordance with articles 3(1a), 4 and 5 of the Transparency Directive or in prospectuses published in accordance with Regulation (EU) 2017/1129 of the European Parliament and of the Council of 14 June 2017.