• SWE FI fined Neongelb Invest and Kringesche Vermögensverwaltungs GmbH for late disclosure of Stillfront Group shares' acquisition, each fine amounts to SEK 2,400,000.

Factual Basis

• Neongelb Invest GmbH (HRB 147961) and Kringesche (HRB 147903) both must pay a fine for late reporting of transactions with shares in Stillfront Group AB to SWE FI.
• Both companies announced on 18 January 2018 they were related to a person in leading position in Stillfront and acquired, free of charge 310,086 shares each, in Stillfront Group on 10 January 2018, notifications have Nasdaq Stockholm as trading venue.
• On the same day both companies corrected notifications regarding trading venue.
• They indicated the transactions had taken place outside the trading venue.
• On 26 March 2018, SWE FI raised issue of whether companies had breached obligation under art 19 of MAR and whether it should therefore intervene against them.
• Both companies stated in opinions they had no excuse, transactions were reported too late due to human error, submitted supporting documents i.e. transaction statements.

Legal Framework and Decisions

• It is responsibility of reporting party to keep itself informed of rules which apply to reporting to SWE FI's transparency register and ensure registration is done on time.
• Notification being delayed due to mistake does not mean violation is excusable.
• Nor does company's representatives problems accessing SWE FI's reporting system.
• Due to size of transactions re infringement, even if short delay in reporting, cannot be considered as minor, neither has SWE FI found reason to refrain from intervention.
• SWE FI thus set fines in SEK 2,400,000, will invoice them when decisions are final.