As part of its listing rules, the UK Listing Authority (UKLA) has produced the Model Code. Listed companies, such as NAHL Group plc, must comply with the Model Code restricting the ability of their senior managers and officers (restricted persons) to deal in the Company’s securities. The Model Code requires restricted persons to seek clearance before buying or selling securities. There are prescribed circumstances when clearance must be refused, including during a close period.

A close period is any of the following:

• The 60 days leading up to a preliminary announcement of the company’s annual results
• The 60 days leading up to publication of the company’s annual financial report
• If the company reports on a half-yearly basis, the period from the end of the relevant financial period until the time of publication
• The 30 days leading up to the publication of quarterly results.