Cross-referenced from Rule 703, Appendix 7A and Practice Note 7A
Part I Introduction
1. This Practice Note provides information on the procedures that issuers may undertake when unusual trading activity in their securities is observed.
2. An issuer's sponsor is responsible for having arrangements to monitor trading activity in the issuer's securities.
Part II Unusual Trading Activity
3. As set out under paragraph 20 of Appendix 7A, unusual trading activity in an issuer's securities, without it being apparent that publicly available information could account for the activity, may signify trading by persons who are acting on unannounced material information or on a rumour or report, whether true or false.
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Part III Role of SGX RegCo
5. SGX RegCo will also review trading activity in the issuer’s securities. If SGX RegCo considers that there is unusual trading activity that is not directly attributable to public information relating to the issuer, industry trends or market sentiment, SGX RegCo may highlight such unusual trading activity to the issuer. The issuer should engage with its sponsor, and consider whether it is aware of any undisclosed material information. If so, it should be disclosed on SGXNET.
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Part IV Reviewing of Unusual Trading Activity
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10. An issuer is expected to review any unusual trading activity in its securities as soon as possible. In view of the importance of maintaining a fair, orderly and transparent market, issuers and sponsors must, upon being made aware of the unusual trading activity, immediately undertake an enquiry to ascertain the cause of the unusual trading activity. Issuers and sponsors should have in place, procedures to ensure that the enquiry or information gathering is carried out efficiently, systematically and promptly, so that the issuer is able to disseminate all material information as soon as possible.
11. Paragraph 22 of Appendix 7A sets out some possible causes for unusual trading and how issuers should respond based on different causes.
12. An issuer may wish to, where appropriate, request for a trading halt or suspension of trading in its securities. If so, the issuer should contact Securities Market Control and provide a SGXNET announcement requesting for a trading halt or suspension, stating the reason for the trading halt or suspension. Where possible, it would be useful for issuers to inform investors when the trading halt or suspension of its securities is expected to be lifted.
13. [Deleted]
Part V Keeping Track of Persons with Access to Material Information
14. Paragraph 13 of Appendix 7A explains that material information, which is otherwise required to be disclosed under Rule 703(1), may be temporarily withheld under Rule 703(3), provided that the strictest confidentiality is maintained.
15. To ensure the confidentiality of the information and as a matter of good corporate governance, where an issuer relies on Rule 703(3) to withhold material information, the issuer must be able to keep track of persons who gained access to the information. These persons may include internal staff or external advisers. The issuer's supervision aids in the control of information flow, as well as assists in investigations in case of information “leaks”.
16. Unusual trading activity observed in an issuer's securities could indicate possible “leaks” of material information. In this circumstance, the Exchange may request the issuer to submit a list of persons who have access to the information (“privy persons list”). The privy persons list should typically include information on the identity of the privy persons, the circumstances under which these persons gained access to the information (i.e. became aware or involved in the transaction), and the dates on which these persons first gained access to the information. The Exchange may also ask for related information reasonably required for the proper discharge of its regulatory function.
17. The issuer must have proper procedures in place to provide the privy persons list expeditiously to the Exchange upon request. Such procedures may include the maintenance of the privy persons list from the date the issuer first started withholding information under Rule 703(3).
Part VI Conclusion
18. This Practice Note sets out the procedures which issuers may undertake when unusual trading activity in their securities is observed. However, there may be instances when a different approach is warranted.
19. Issuers should also familiarize themselves with the Exchange's Continuing Obligations, Corporate Disclosure Policy and any other relevant Practice Notes.
20. Issuers should consult their sponsors if they have queries on this matter.
Amended on 3 March 2014, 1 December 2015, 15 September 2017 and 29 October 2025.