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

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.

ESMA reminds issuers that, according to paragraph 41 of the APM Guidelines, the definition and calculation of an APM should be consistent over time. Therefore, ESMA recommends that issuers use caut

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