Final Notice
1
FINAL NOTICE
To:
Asia Research and Capital Management Ltd
1.
ACTION
1.1.
For the reasons given in this Final Notice, the Authority hereby imposes on Asia
Research and Capital Management Ltd (“ARCM”) a financial penalty of £873,118
pursuant to section 131G of the Act.
1.2.
ARCM agreed to resolve this matter and qualified for a 30% (stage 1) discount
under the Authority’s executive settlement procedures. Were it not for this
discount, the Authority would have imposed a financial penalty of £1,247,312.25
on ARCM.
2.
SUMMARY OF REASONS
2.1.
In 2012, Regulation (EU) No 236/2012 of the European Parliament and of the
Council of 14 March 2012 on short selling and certain aspects of credit default
swaps (“SSR”) introduced requirements to notify the Authority and disclose to the
public details of net short positions held. The purpose of the SSR is to improve
transparency within financial markets, and support effective markets that operate
with integrity. Short selling activity can play an important role in ensuring the
proper functioning of financial markets, in particular it can contribute to market
liquidity and efficient price formation. However, short selling activity also has the
potential to create systemic risks, be abusive, or create disorderly markets. The
SSR enables enhanced transparency in relation to short selling activity, so that
the information on net short positions that the Authority receives allows it to
monitor and identify these risks. Likewise, market participants can benefit from
net short positions publicly disclosed as this may inform investment decisions.
Failing to comply with the obligations under the SSR could potentially disrupt the
proper functioning of financial markets, in particular, in the context of market
liquidity and efficient price formation.
2.2.
ARCM is an asset management firm based in Hong Kong, which manages a series
of long duration closed-end investment vehicles focused primarily on investing in
debt and equity securities across Asia, and which infrequently trades in EU
markets.
2.3.
The Authority has taken this action because, between 22 February 2017 and 3
December 2019 (“the Relevant Period”), ARCM:
(1)
failed to make 155 notifications of its net short position to the Authority in
accordance with the method required under Article 9 of the SSR, in breach
of Article 5 of the SSR; and
(2)
failed to make 153 disclosures of its net short position to the public in
accordance with the method required under Article 9, in breach of Article 6
of the SSR.
2.4.
The Authority considers ARCM’s failings to be particularly serious given:
(1)
the failures to comply with its obligations under the SSR were multiple, and
occurred over a long period of time;
(2)
ARCM did not inform the Authority promptly upon discovering its failure to
comply with the relevant obligations under the SSR, and instead notified the
Authority only after it had reviewed and collated the relevant data for
disclosure; and
(3)
the size of the position, as demonstrated by the fact that, as at the date of
this notice, ARCM’s final net short position was the largest net short position
held in an issuer admitted to the Authority’s Official List with shares admitted
to trading on the Main Market of the London Stock Exchange.
2.5.
The Authority notes that ARCM has since sought to remediate its underlying
systems and controls related to the SSR, and has fully co-operated with the
Authority’s investigation over the period of the COVID-19 global pandemic.
3
2.6.
The Authority hereby imposes on ARCM a financial penalty of £873,118 pursuant
to section 131G of the Act.
3.
DEFINITIONS
3.1.
The definitions below are used in this Notice:
“the Act” means the Financial Services and Markets Act 2000;
“ARCM” means Asia Research and Capital Management Ltd;
“the Authority” means the Financial Conduct Authority;
“DEPP” means the part of the Authority’s Handbook entitled Decision, Procedures
and Penalties Manual;
“Premier Oil” means Premier Oil Plc, a Premium Listed issuer admitted to the
Authority’s Official List and with shares admitted to trading on the Main Market of
the London Stock Exchange;
“the Relevant Period” means the period from 22 February 2017 to 3 December
2019; and
“SSR” means Regulation (EU) No 236/2012 of the European Parliament and of the
Council of 14 March 2012 on short selling and certain aspects of credit default
swaps.
4.
FACTS AND MATTERS
Obligations under the SSR
4.1.
The SSR imposes obligations on all market participants trading in financial
instruments for which the Authority is the relevant competent authority, wherever
they are domiciled or established.
4.2.
The SSR applies to any transferable security such as shares. It also states that a
short position includes a transaction related to a share which gives the effect of
conferring a financial advantage on the person entering into it in the event of a
decrease in the price of the share. This would include derivatives such as equity
swaps and contracts for difference relating to shares which replicated the effects
of a short sale of the share itself.
4.3.
For the purpose of the SSR, a net short position in relation to shares of an issuer
is the position which results from the difference between any short position and
any long position held by a market participant in relation to the issued share
capital of an issuer.
4.4.
Where a market participant holds a net short position in a share admitted to
trading on any trading venue in the UK, it has the following obligations:
(1)
if the net short position is equivalent to 0.2% of an issuer’s issued share
capital, it must report this to the Authority;
(2)
for every increase of that net short position equivalent to 0.1% of an issuer’s
share capital, it must make a further notification to the Authority;
(3)
if the net short position is equivalent to 0.5% of the issuer’s share capital,
it must be made public, through publication on a website maintained by the
Authority. In practice, this requires the market participant to make the
notification to the Authority; and
(4)
for every increase of that net short position equivalent to 0.1% of an issuer’s
share capital, it must make further disclosure to the public via its notification
to the Authority.
4.5.
A market participant should calculate whether it has passed the notification
threshold, by calculating the size of the net short position as at midnight on the
day on which it holds the position.
4.6.
The notification must be made to the Authority by 15:30 UK time on the following
trading day.
The investment in Premier Oil
4.7.
On 17 October 2016, ARCM began investing in Premier Oil through the acquisition
of a debt instrument, via a secondary market transaction. From this date, ARCM
built its credit position in Premier Oil and continued to do so throughout the
Relevant Period.
4.8.
Between 22 and 23 February 2017, ARCM entered into two equity swap
transactions in Premier Oil for the purpose of hedging its credit risk exposure, in
connection with its investment strategy. In both instances, this caused ARCM’s
net short position to be equivalent to 0.2% or above, thereby triggering its
obligation to notify the Authority under Article 5 of the SSR by 15:30 (UK time)
on the following trading day. ARCM failed to notify the Authority in both instances
as required. The notifications to the Authority were not made until 3 December
2019.
4.9.
On 24 February 2017, ARCM entered into a further equity swap transaction in
Premier Oil for the same purpose of hedging its credit risk exposure. This
transaction caused ARCM’s net short position to equal 0.53% of Premier Oil’s
issued share capital, triggering its first obligation under Article 6 of the SSR to
disclose its position to the public. ARCM failed to disclose this position to the public
by 15:30 (UK time) on the following trading day, as required.
4.10.
In total, from 24 February 2017 to 5 July 2019, ARCM failed to make 153
notifications to the Authority in relation to its net short position in Premier Oil’s
issued share capital which were required to be disclosed to the Authority and/or
to the public. The full list of these can be found in Annex B of this Notice. As can
be seen in Annex B, ARCM failed to disclose on 153 occasions the change in its
net short position to the Authority and/or to the public as required, by 15:30 (UK
time) on the following trading day. It was not until after market close on 3
December 2019 that all 153 notifications were made to the Authority, and
consequently were not disclosed to the public until after close of business on the
next trading day, 4 December 2019.
4.11.
By 5 July 2019, ARCM had built a net short position equivalent to 16.85% of
Premier Oil’s issued share capital via equity swaps. This net short position in
Premier Oil was then held by ARCM for a further 106 trading days before being
notified to the Authority and disclosed to the public.
4.12.
As at the date of this notice, ARCM’s final undisclosed net short position,
equivalent to 16.85% of Premier Oil’s issued share capital, was the largest net
short position ever held in an issuer admitted to the Authority’s Official List with
shares admitted to trading on the Main Market of the London Stock Exchange.
The compliance environment at ARCM
4.13.
Throughout the Relevant Period, ARCM had in place a trading compliance
management system that integrated pre- and post-trade controls; this included
consideration of the applicable rules and regulations governing the investment
before it was made. ARCM’s investment in Premier Oil and the associated short
position taken were assessed through this compliance process.
4.14.
In relation to Premier Oil, the effectiveness of these systems and controls was
impacted by the fact that, as a result of its investment strategy, ARCM traded
infrequently in EU markets. Specifically, ARCM had very infrequently taken short
positions in companies in EU markets.
4.15.
In ascertaining its obligations in advance of the trading, ARCM relied on third party
materials about the regulatory context in the UK. Although this contained
information concerning the SSR, the materials included an indicative, rather than
an exhaustive, list of the instruments to which the SSR applied. Specifically, and
consistent with the regulatory position in non-EU jurisdictions where ARCM
operates, it did not reference derivatives trading as requiring notification. ARCM
therefore incorrectly believed that the obligation did not apply to its trading in
Premier Oil. Consequently, it did not conduct any further due diligence regarding
the extent of the obligation, or its application to these trades.
4.16.
As a result, ARCM failed to identify the application of the SSR to its net short
position held through a swap in Premier Oil, and therefore failed to identify the
requirement to report.
Discovery of the SSR obligations and notification to the Authority
4.17.
As a result of the deficiencies in the compliance process, it was not until 29
October 2019 that ARCM became aware of the obligation to report short selling
activity through swaps in the UK and that the net short position it held in Premier
Oil might also be subject to those obligations. ARCM sought to confirm this
through further analysis.
4.18.
Between 29 October 2019 and 8 November 2019, ARCM took steps to ascertain
whether the SSR indeed applied to the net short position it held, whether any
exemptions were applicable, and the precise disclosure obligations and notification
procedures.
4.19.
On 8 November 2019, ARCM determined that it did in fact have an obligation to
make the disclosures. As a result, ARCM immediately began preparing the data
and notifications/disclosures required under the SSR and instituted a process to
ensure that the notifications/disclosures made were comprehensive and accurate,
reflecting the full history of the position. This involved engaging external
consultants to conduct a verification exercise of the data and draft filings. ARCM’s
work was delayed and disrupted by the social unrest in Hong Kong at the time, as
7
a result of which ARCM staff members involved in the collection of the required
data for the preparation of filings were not able to access the office for several
days. Similar disruptions were also experienced by the external consultants in the
conduct of their work. While this exercise in preparing the correct information was
undertaken, ARCM did not inform the Authority of the existence of the breaches.
4.20.
It was not until 29 November 2019 that ARCM notified the Authority that it had
failed to make a significant number of notifications in relation to its net short
position held in Premier Oil, and that it would be submitting these net short
position notifications to the Authority as soon as it could. During the evening of 3
December 2019, ARCM submitted 155 notifications in relation to its net short
position held in Premier Oil’s issued share capital.
4.21.
ARCM identified that 153 of these net short position notifications were equivalent
to 0.5% of Premier Oil’s issued share capital and above, which triggered its
obligation to also disclose them to the public. After close of business on
Wednesday 4 December 2019, 153 of the 155 net short position notifications were
disclosed to the public on the Authority’s website.
4.22.
Over the weekend following the disclosures being made public, press articles
commented on the late disclosures made by ARCM. As a result of ARCM’s failure
to make disclosures in accordance with the time limits set out in the SSR, the
market functioned during the Relevant Period without information that should
have been available to it but was not. This inherently has an impact on market
confidence and transparency.
5.
FAILINGS
5.1.
The regulatory provisions relevant to this Notice are referred to in Annex A.
5.2.
The contraventions are a result of ARCM’s failure to identify its obligations under
the SSR.
Article 5 of SSR
5.3.
Article 5(1) and (2) of SSR require a market participant that has a net short
position which is equivalent to 0.2% of an issuer’s issued share capital, and each
0.1% above that, to notify the Authority in accordance with Article 9.
5.4.
Between 22 February 2017 and 5 July 2019, ARCM failed to make 155 notifications
of its net short position in the issued share capital of Premier Oil to the Authority,
as required by Article 5(1) and (2) of SSR, in accordance with Article 9.
Article 6 of SSR
5.5.
Article 6(1) and (2) of SSR require a market participant that has a net short
position which is equivalent to 0.5% of an issuer’s issued share capital, and each
0.1% above that, to disclose details of that position to the public in accordance
with Article 9. The disclosure should be made to the Authority for publication on
the Authority’s website.
5.6.
Between 24 February 2017 and 5 July 2019, ARCM failed to make 153 disclosures
of its net short position in the issued share capital of Premier Oil to the public, as
required by Article 6(1) and (2) of SSR, in accordance with Article 9.
6.
SANCTION
Financial penalty
6.1.
The Authority’s policy for imposing a financial penalty is set out in Chapter 6 of
DEPP. In respect of conduct occurring on or after 6 March 2010, the Authority
applies a five-step framework to determine the appropriate level of financial
penalty. DEPP 6.5A sets out the details of the five-step framework that applies in
respect of financial penalties imposed on firms.
Step 1: disgorgement
6.2.
Pursuant to DEPP 6.5A.1G, at Step 1 the Authority seeks to deprive a firm of the
financial benefit derived directly from the breach where it is practicable to quantify
this.
6.3.
The Authority has not identified any financial benefit that ARCM derived directly
from its breach. Step 1 is therefore £0.
Step 2: the seriousness of the breach
6.4.
Pursuant to DEPP 6.5A.2G, at Step 2 the Authority determines a figure that
reflects the seriousness of the breach. The Authority considers that the cumulative
value of the percentage of issued share capital, equal to the short positions held
by ARCM during the Relevant Period, is an appropriate indicator of the harm or
potential harm caused by its breach. The Authority considers the cumulative value
of the percentage of issued share capital equal to the short positions held during
the Relevant Period to be £332,616,518.
6.5.
The Authority has determined the seriousness of ARCM’s breaches to be Level 3
for the purposes of Step 2 having taken into account:
(1)
DEPP 6.5A.2G (6-9) which lists the factors the Authority will generally take
into account in deciding which level of penalty best indicates the seriousness
of the breach;
(2)
DEPP 6.5A.2G (11) which lists the factors likely to be considered ‘Level 4 or
5 factors’; and
(3)
DEPP 6.5A.2G (12) which lists the factors likely to be considered ‘Level 1, 2
or 3 factors’.
6.6.
Of these, the Authority considers the following factors to be relevant:
(1)
it is important that firms make notifications to the Authority and disclosures
to the public of net short positions in compliance with the obligations under
the SSR, as this improves transparency within financial markets, contributes
to price formation and supports effective markets that operate with
integrity;
(2)
the breaches are considered to be serious because they have revealed
weaknesses in ARCM’s procedures, management systems and internal
controls to comply with its obligations under the SSR insofar as they relate
to specific types of derivative interests;
(3)
the breaches are considered to be serious as they were multiple and
occurred over a significant period of time, notwithstanding that they
stemmed from the same root cause failure in ARCM’s compliance
environment; and
(4)
the breaches were not committed deliberately or recklessly.
6.7.
The Authority has applied the following percentages to the seriousness factors
considered above, for firms in breach of the SSR:
Level 1 – 0%
Level 2 – 0.25%
Level 3 – 0.5%
Level 4 – 0.75%
Level 5 – 1%
6.8.
As a seriousness factor of 3 is appropriate, the Step 2 figure is therefore 0.5% of
£332,616,518, which is £1,663,083.
6.9.
DEPP 6.5.3G(3) states that the Authority recognises that a penalty must be
proportionate to the breach. The Authority may decrease the level of penalty
arrived at after applying Step 2 of the framework if it considers that the penalty
is disproportionately high for the breach concerned. In this case the Authority
considers that the Step 2 figure is disproportionately high when looking at the
totality of ARCM’s misconduct overall, given that the breaches stemmed from the
same root cause failure in ARCM’s compliance environment, and should be
adjusted. In order to achieve a penalty (at Step 2) that is proportionate to the
breach, the Step 2 figure is reduced by 25% to £1,247,312.25.
6.10.
Step 2 is therefore £1,247,312.25.
Step 3: mitigating and aggravating factors
6.11.
Pursuant to DEPP 6.5A.3G, at Step 3 the Authority may increase or decrease the
amount of the financial penalty arrived at after Step 2, but not including any
amount to be disgorged as set out in Step 1, to take into account factors which
aggravate or mitigate the breach.
6.12.
The Authority considers that the following factors aggravate the breach:
(1)
ARCM did not inform the Authority promptly upon discovering its failure to
comply with its obligations under the SSR and instead notified the Authority
only after it had reviewed and collated the relevant data for disclosure; and
(2)
the size of the final position, as demonstrated by the fact that, as at the
date of this notice, it was the largest short position held in an issuer admitted
to the Authority’s Official List with shares admitted to trading on the Main
Market of the London Stock Exchange.
6.13.
The Authority considers that the following factors mitigate the breach:
(1)
ARCM self-identified all of its failures to comply with the SSR; and
(2)
ARCM has no previous disciplinary history in the UK or in Hong Kong.
6.14.
Having taken into account these aggravating and mitigating factors, the Authority
does not consider that the Step 2 figure should be increased or decreased.
6.15.
Step 3 is therefore £1,247,312.25.
Step 4: adjustment for deterrence
6.16.
Pursuant to DEPP 6.5A.4G, if the Authority considers that the figure arrived at
after Step 3 is insufficient to deter the firm who committed the breach, or others,
from committing further or similar breaches, then the Authority may increase the
penalty.
6.17.
The Authority considers that the Step 3 figure of £1,247,312.25 represents a
sufficient deterrent to ARCM and others, and so has not increased the penalty at
Step 4.
6.18.
Step 4 is therefore £1,247,312.25.
Step 5: settlement discount
6.19.
Pursuant to DEPP 6.5A.5G, if the Authority and the firm on whom a penalty is to
be imposed agree the amount of the financial penalty and other terms, DEPP 6.7
provides that the amount of the financial penalty which might otherwise have
been payable will be reduced to reflect the stage at which the Authority and the
firm reached agreement. The settlement discount does not apply to the
disgorgement of any benefit calculated at Step 1.
6.20.
The Authority and ARCM reached agreement at Stage 1 and so a 30% discount
applies to the Step 4 figure.
6.21.
Step 5 is therefore £873,118.
Penalty
6.22.
The Authority hereby imposes a total financial penalty of £873,118 on ARCM for
breaches of the SSR.
7.
PROCEDURAL MATTERS
7.1.
This Notice is given to ARCM under section 131G and in accordance with the
section 390 of the Act.
7.2.
The following statutory rights are important.
Decision maker
7.3.
The decision which gave rise to the obligation to give this Notice was made by the
Settlement Decision Makers.
Manner and time for payment
7.4.
The financial penalty must be paid in full by ARCM to the Authority no later than
29 October 2020.
If the financial penalty is not paid
7.5.
If all or any of the financial penalty is outstanding on 29 October 2020, the
Authority may recover the outstanding amount as a debt owed by ARCM and due
to the Authority.
Publicity
7.6.
Sections 391(4), 391(6) and 391(7) of the Act apply to the publication of
information about the matter to which this notice relates. Under those provisions,
the Authority must publish such information about the matter to which this notice
relates as the Authority considers appropriate. The information may be published
in such manner as the Authority considers appropriate. However, the Authority
may not publish information if such publication would, in the opinion of the
Authority, be unfair to ARCM or prejudicial to the interests of consumers or
detrimental to the stability of the UK financial system.
Authority contacts
7.7.
For more information concerning this matter generally, contact Caroline Ryan at
the Authority (direct line: 020 7066 3702/email: Caroline.Ryan@fca.org.uk).
Director
Financial Conduct Authority, Enforcement and Market Oversight Division
ANNEX A
RELEVANT STATUTORY AND REGULATORY PROVISIONS
RELEVANT LEGISLATIVE PROVISIONS
The Financial Services and Markets Act 2000 (“the Act”)
1.1.
The Authority’s statutory objectives, set out in section 1B(3) of the Act, include the
integrity objective, to protect and enhance the integrity of the UK financial system.
1.2.
Section 131G of the Act provides:
“if the [Authority] is satisfied that a person has contravened any provision of the
short selling regulation…it may impose a penalty of such amount as it considers
appropriate on the person who contravened the provision or requirement”.
Regulation (EU) No 236/2012 of the European Parliament and of the Council of
14 March 2012 on short selling and certain aspects of credit default swaps
(“SSR”)
1.3.
The European Parliament and the Council of the European Union agreed that it was
appropriate to lay down a common regulatory framework with regard to the
requirements and powers relating to short selling and credit default swaps and to
ensure greater coordination and consistency between Member States where
measures have to be taken in exceptional circumstances. The SSR was
implemented to ensure the proper functioning of the internal market and to
improve the conditions of its functioning, in particular with regard to the financial
markets, and to ensure a high level of consumer and investor protection. The
relevant Articles are as follows.
1.4.
Article 5 SSR states:
“(1) A natural or legal person who has a net short position in relation to the issued
share capital of a company that has shares admitted to trading on a trading venue
shall notify the relevant competent authority, in accordance with Article 9, where
the position reaches or falls below a relevant notification threshold referred to in
paragraph 2 of this Article.
(2) A relevant notification threshold is a percentage that equals 0.2% of the issued
share capital of the company concerned and each 0.1% above that.”
1.5.
Article 6 SSR states:
“(1) A natural or legal person who has a net short position in relation to the issued
share capital of a company that has shares admitted to trading on a trading venue
shall disclose details of that position to the public, in accordance with Article 9,
where the position reaches or falls below a relevant publication threshold referred
to in paragraph 2 of this Article.
(2) A relevant notification threshold is a percentage that equals 0.5% of the issued
share capital of the company concerned and each 0.1% above that.”
1.6.
Article 9 SSR states:
“(1) Any notification or disclosure under Article 5, 6, 7 or 8 shall set out details of
the identity of the natural or legal person who holds the relevant position, the size
of the relevant position, the issuer in relation to which the relevant position is held
and the date on which the relevant position was created, changed or ceased to be
held.
(2) The relevant time for calculation of a net short position shall be at midnight at
the end of the trading day on which the natural or legal person holds the relevant
position. That time shall apply to all transactions irrespective of the means of
trading used, including transactions executed through manual or automated
trading, and irrespective of whether the transactions have taken place during
normal trading hours. The notification or disclosure shall be made not later than at
15.30 on the following trading day. The time specified in this paragraph shall be
calculated according to the time in the Member State of the relevant competent
authority to whom the relevant position must be notified.”
RELEVANT REGULATORY PROVISIONS
Decision Procedures and Penalties Manual (“DEPP”)
1.7.
Chapter 6 of DEPP, which forms part of the Authority’s Handbook, sets out the
Authority’s statement of policy with respect to the imposition and amount of
financial penalties under the Act.
The Enforcement Guide
1.8.
The Enforcement Guide sets out the Authority’s approach to exercising its main
enforcement powers under the Act.
1.9.
Chapter 7 of the Enforcement Guide sets out the Authority’s approach to exercising
its power to impose a financial a penalty.
ANNEX B
Position date Number
of
equivalent
shares
%
of
issued
share
capital
Date position
should
have
been
notified
to
the
Authority and
disclosed
to
the public - by
15:30
(UK
time) Articles
5, 6 & 9 SSR
Date notified
to
the
Authority
Article
5
SSR
(*each
notification
was
made
post-15:30)
Date
disclosed
to
the
public
Article
6
1
24/02/2017
2,745,848
0.53
27/02/2017
03/12/2019*
04/12/2019
2
27/02/2017
3,841,731
0.75
28/02/2017
03/12/2019*
04/12/2019
3
28/02/2017
4,388,163
0.85
01/03/2017
03/12/2019*
04/12/2019
4
01/03/2017
7,452,947
1.45
02/03/2017
03/12/2019*
04/12/2019
5
02/03/2017
8,972,295
1.75
03/03/2017
03/12/2019*
04/12/2019
6
03/03/2017
10,088,114
1.97
06/03/2017
03/12/2019*
04/12/2019
7
06/03/2017
10,490,524
2.05
07/03/2017
03/12/2019*
04/12/2019
9
08/03/2017
13,186,224
2.58
09/03/2017
03/12/2019*
04/12/2019
12
15/03/2017
16,658,454
3.26
16/03/2017
03/12/2019*
04/12/2019
13
17/03/2017
18,325,567
3.58
20/03/2017
03/12/2019*
04/12/2019
14
20/03/2017
19,196,807
3.75
21/03/2017
03/12/2019*
04/12/2019
20
21/04/2017
23,874,708
4.67
24/04/2017
03/12/2019*
04/12/2019
23
26/04/2017
25,773,408
5.04
27/04/2017
03/12/2019*
04/12/2019
24
02/05/2017
26,079,403
5.10
03/05/2017
03/12/2019*
04/12/2019
25
04/05/2017
26,995,190
5.28
05/05/2017
03/12/2019*
04/12/2019
26
05/05/2017
27,278,763
5.34
08/05/2017
03/12/2019*
04/12/2019
27
09/05/2017
27,680,472
5.41
10/05/2017
03/12/2019*
04/12/2019
28
19/05/2017
28,277,387
5.53
22/05/2017
03/12/2019*
04/12/2019
29
31/05/2017
28,904,687
5.65
01/06/2017
03/12/2019*
04/12/2019
30
15/06/2017
29,278,287
5.73
16/06/2017
03/12/2019*
04/12/2019
31
16/06/2017
29,671,887
5.80
19/06/2017
03/12/2019*
04/12/2019
32
22/06/2017
30,501,591
5.97
23/06/2017
03/12/2019*
04/12/2019
33
23/06/2017
31,197,762
6.10
26/06/2017
03/12/2019*
04/12/2019
34
03/07/2017
31,713,201
6.20
04/07/2017
03/12/2019*
04/12/2019
35
12/07/2017
31,029,689
6.07
13/07/2017
03/12/2019*
04/12/2019
36
28/07/2017
30,523,639
5.97
31/07/2017
03/12/2019*
04/12/2019
37
05/09/2017
30,299,072
5.89
06/09/2017
03/12/2019*
04/12/2019
38
14/11/2017
30,235,256
5.79
15/11/2017
03/12/2019*
04/12/2019
39
15/11/2017
30,483,087
5.83
16/11/2017
03/12/2019*
04/12/2019
40
05/12/2017
30,434,292
5.79
06/12/2017
03/12/2019*
04/12/2019
41
12/01/2018
30,063,964
5.69
15/01/2018
03/12/2019*
04/12/2019
42
19/01/2018
30,063,964
3.93
22/01/2018
03/12/2019*
04/12/2019
43
12/02/2018
30,974,781
4.03
13/02/2018
03/12/2019*
04/12/2019
46
16/02/2018
34,021,520
4.43
19/02/2018
03/12/2019*
04/12/2019
47
01/03/2018
34,613,326
4.50
02/03/2018
03/12/2019*
04/12/2019
48
02/03/2018
35,625,326
4.63
05/03/2018
03/12/2019*
04/12/2019
49
08/03/2018
36,995,121
4.81
09/03/2018
03/12/2019*
04/12/2019
50
29/05/2018
36,845,299
4.79
30/05/2018
03/12/2019*
04/12/2019
51
07/06/2018
35,848,599
4.66
08/06/2018
03/12/2019*
04/12/2019
52
11/06/2018
34,703,046
4.51
12/06/2018
03/12/2019*
04/12/2019
53
12/06/2018
33,686,112
4.38
13/06/2018
03/12/2019*
04/12/2019
54
14/06/2018
32,562,288
4.23
15/06/2018
03/12/2019*
04/12/2019
56
18/06/2018
30,531,227
3.97
19/06/2018
03/12/2019*
04/12/2019
57
19/06/2018
29,710,469
3.86
20/06/2018
03/12/2019*
04/12/2019
58
20/06/2018
28,503,698
3.70
21/06/2018
03/12/2019*
04/12/2019
59
21/06/2018
28,415,746
3.69
22/06/2018
03/12/2019*
04/12/2019
60
22/06/2018
27,654,120
3.59
25/06/2018
03/12/2019*
04/12/2019
61
29/06/2018
26,436,220
3.43
02/07/2018
03/12/2019*
04/12/2019
62
03/07/2018
25,922,233
3.34
04/07/2018
03/12/2019*
04/12/2019
63
11/07/2018
25,498,196
3.28
12/07/2018
03/12/2019*
04/12/2019
64
12/07/2018
24,116,184
3.11
13/07/2018
03/12/2019*
04/12/2019
65
23/07/2018
23,957,784
3.09
24/07/2018
03/12/2019*
04/12/2019
69
29/08/2018
23,348,885
3.00
30/08/2018
03/12/2019*
04/12/2019
70
05/09/2018
24,362,684
3.10
06/09/2018
03/12/2019*
04/12/2019
72
07/09/2018
25,019,876
3.06
10/09/2018
03/12/2019*
04/12/2019
74
22/10/2018
26,848,322
3.29
23/10/2018
03/12/2019*
04/12/2019
75
23/10/2018
28,194,322
3.45
24/10/2018
03/12/2019*
04/12/2019
76
24/10/2018
29,234,265
3.58
25/10/2018
03/12/2019*
04/12/2019
77
25/10/2018
30,357,839
3.72
26/10/2018
03/12/2019*
04/12/2019
78
26/10/2018
31,827,039
3.90
29/10/2018
03/12/2019*
04/12/2019
79
30/10/2018
33,263,531
4.07
31/10/2018
03/12/2019*
04/12/2019
80
31/10/2018
34,230,496
4.19
01/11/2018
03/12/2019*
04/12/2019
81
01/11/2018
34,592,016
4.23
02/11/2018
03/12/2019*
04/12/2019
82
02/11/2018
36,069,516
4.42
05/11/2018
03/12/2019*
04/12/2019
83
05/11/2018
37,295,272
4.57
06/11/2018
03/12/2019*
04/12/2019
84
08/11/2018
38,149,458
4.67
09/11/2018
03/12/2019*
04/12/2019
85
12/11/2018
43,027,423
5.27
13/11/2018
03/12/2019*
04/12/2019
86
13/11/2018
44,587,423
5.46
14/11/2018
03/12/2019*
04/12/2019
87
14/11/2018
47,012,923
5.76
15/11/2018
03/12/2019*
04/12/2019
88
15/11/2018
49,477,723
6.06
16/11/2018
03/12/2019*
04/12/2019
89
16/11/2018
52,139,723
6.38
19/11/2018
03/12/2019*
04/12/2019
90
19/11/2018
54,515,484
6.68
20/11/2018
03/12/2019*
04/12/2019
91
20/11/2018
57,090,020
6.99
21/11/2018
03/12/2019*
04/12/2019
92
21/11/2018
59,250,447
7.26
22/11/2018
03/12/2019*
04/12/2019
94
23/11/2018
62,855,994
7.70
29/11/2018
03/12/2019*
04/12/2019
95
26/11/2018
64,993,695
7.96
27/11/2018
03/12/2019*
04/12/2019
100 06/12/2018
71,546,306
8.75
07/12/2018
03/12/2019*
04/12/2019
102 11/12/2018
75,298,704
9.21
12/12/2018
03/12/2019*
04/12/2019
105 17/12/2018
79,768,871
9.76
18/12/2018
03/12/2019*
04/12/2019
107 19/12/2018
82,261,924
10.06
20/12/2018
03/12/2019*
04/12/2019
108 20/12/2018
83,416,983
10.20
21/12/2018
03/12/2019*
04/12/2019
109 21/12/2018
84,807,383
10.37
24/12/2018
03/12/2019*
04/12/2019
110 24/12/2018
85,021,597
10.40
27/12/2018
03/12/2019*
04/12/2019
111 13/03/2019
85,021,597
10.34
14/03/2019
03/12/2019*
04/12/2019
112 26/04/2019
86,163,597
10.48
29/04/2019
03/12/2019*
04/12/2019
113 29/04/2019
87,269,041
10.62
30/04/2019
03/12/2019*
04/12/2019
114 30/04/2019
88,212,367
10.70
01/05/2019
03/12/2019*
04/12/2019
115 02/05/2019
89,258,591
10.82
03/05/2019
03/12/2019*
04/12/2019
116 07/05/2019
90,293,591
10.95
08/05/2019
03/12/2019*
04/12/2019
117 08/05/2019
90,892,247
11.02
09/05/2019
03/12/2019*
04/12/2019
118 09/05/2019
91,553,247
11.10
10/05/2019
03/12/2019*
04/12/2019
119 13/05/2019
92,338,699
11.20
14/05/2019
03/12/2019*
04/12/2019
120 15/05/2019
93,217,699
11.30
16/05/2019
03/12/2019*
04/12/2019
121 16/05/2019
94,673,699
11.48
17/05/2019
03/12/2019*
04/12/2019
122 17/05/2019
95,473,699
11.58
20/05/2019
03/12/2019*
04/12/2019
123 20/05/2019
96,067,699
11.65
21/05/2019
03/12/2019*
04/12/2019
124 21/05/2019
96,473,699
11.70
22/05/2019
03/12/2019*
04/12/2019
125 23/05/2019
97,501,799
11.82
24/05/2019
03/12/2019*
04/12/2019
126 28/05/2019
98,806,799
11.98
29/05/2019
03/12/2019*
04/12/2019
127 29/05/2019
100,402,799
12.18
30/05/2019
03/12/2019*
04/12/2019
128 30/05/2019
100,879,799
12.23
31/05/2019
03/12/2019*
04/12/2019
129 31/05/2019
102,991,799
12.49
03/06/2019
03/12/2019*
04/12/2019
130 03/06/2019
105,154,712
12.75
04/06/2019
03/12/2019*
04/12/2019
131 04/06/2019
106,990,384
12.97
05/06/2019
03/12/2019*
04/12/2019
132 05/06/2019
109,831,408
13.32
06/06/2019
03/12/2019*
04/12/2019
133 06/06/2019
111,323,725
13.50
07/06/2019
03/12/2019*
04/12/2019
134 07/06/2019
112,804,025
13.68
10/06/2019
03/12/2019*
04/12/2019
135 10/06/2019
113,995,749
13.82
11/06/2019
03/12/2019*
04/12/2019
136 11/06/2019
116,130,749
14.08
12/06/2019
03/12/2019*
04/12/2019
137 12/06/2019
117,814,771
14.29
13/06/2019
03/12/2019*
04/12/2019
138 13/06/2019
119,514,771
14.49
14/06/2019
03/12/2019*
04/12/2019
139 14/06/2019
122,257,771
14.83
17/06/2019
03/12/2019*
04/12/2019
140 17/06/2019
125,082,771
15.17
18/06/2019
03/12/2019*
04/12/2019
141 18/06/2019
127,957,771
15.52
19/06/2019
03/12/2019*
04/12/2019
142 19/06/2019
129,041,771
15.65
20/06/2019
03/12/2019*
04/12/2019
143 20/06/2019
130,121,771
15.78
21/06/2019
03/12/2019*
04/12/2019
144 21/06/2019
131,141,771
15.90
24/06/2019
03/12/2019*
04/12/2019
145 24/06/2019
132,171,771
16.03
25/06/2019
03/12/2019*
04/12/2019
146 25/06/2019
133,224,071
16.16
26/06/2019
03/12/2019*
04/12/2019
147 26/06/2019
134,284,071
16.29
27/06/2019
03/12/2019*
04/12/2019
148 27/06/2019
135,291,071
16.41
28/06/2019
03/12/2019*
04/12/2019
149 28/06/2019
136,291,071
16.53
01/07/2019
03/12/2019*
04/12/2019
150 01/07/2019
136,291,071
16.42
02/07/2019
03/12/2019*
04/12/2019
151 03/07/2019
138,075,994
16.64
04/07/2019
03/12/2019*
04/12/2019
152 04/07/2019
139,070,172
16.76
05/07/2019
03/12/2019*
04/12/2019
153 05/07/2019
139,839,949
16.85
08/07/2019
03/12/2019*
04/12/2019