Date last updated: April 2022

Question: Do the APM Guidelines apply to financial measures related to ESG matters (e.g., green turnover, sustainable CAPEX)?

Answer: According to paragraph 3 of the APM Guidelines, the Guidelines apply in relation to APMs disclosed by issuers or persons responsible for the prospectus when publishing regulated information and prospectuses (and supplements to prospectuses). Examples of regulated information are management reports disclosed to the market in accordance with the Transparency Directive and disclosures issued under the requirements of Article 17 of the Market Abuse Regulation, for example ad-hoc disclosures including financial earnings results.

Furthermore, paragraph 4 clarifies that the APM Guidelines do not apply to APMs disclosed in accordance with applicable legislation, other than the

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