Cross-referenced from Listing Rule 703, Appendix 7.1 and Practice Note 7.1
1. Introduction
1.1 This Practice Note provides information on the procedures that issuers may undertake when unusual trading activity in their securities is observed.
2. Unusual Trading Activity
2.1 As set out under Paragraph 18 of Appendix 7.1, 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.
2.2 [Deleted]
3. Role of SGX RegCo
3.1 SGX RegCo will 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 consider whether it is aware of any undisclosed material information. If so, it should be disclosed on SGXNET.
3.2 [Deleted]
3.3 [Deleted]
4. Reviewing of Unusual Trading Activity
4.1 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 must, upon being made aware of the unusual trading activity, immediately undertake an enquiry to ascertain the cause of the unusual trading activity. Issuers 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.
4.2 Paragraph 20 of Appendix 7.1 sets out some possible causes for unusual trading and how issuers should respond based on different causes.
4.3 An issuer may wish to, where appropriate, request for suspension of trading in its securities or a trading halt. If so, the issuer should contact Securities Market Control and provide a SGXNET announcement requesting for suspension or a trading halt, stating the reason for the suspension or trading halt. Where possible, it would be useful for issuers to inform investors when the suspension of its securities or trading halt is expected to be lifted.
4.4 [Deleted]
5. Secondary Listings and Issuers that are Exempted from Continuing Listing Obligations
5.1 Issuers with a secondary listing on the Exchange and issuers that are exempted from the continuing listing obligations under Chapter 7 must comply with the home exchanges' disclosure requirements. Nevertheless, as the securities of such issuers are being traded on the Exchange, the Exchange must ensure that there is a fair, orderly and transparent market in these securities. Issuers may therefore be required to undertake a review regarding the trading of their securities on the Exchange.
6. Keeping Track of Persons with Access to Material Information
6.1 Paragraph 12 of Appendix 7.1 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.
6.2 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".
6.3 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.
6.4 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 Listing Rule 703(3).
7. Conclusion
7.1 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.
7.2 Issuers should also familiarize themselves with the Exchange's Continuing Obligations, Corporate Disclosure Policy and any other relevant Practice Notes.
Amended on 29 September 2011, 3 March 2014, 1 December 2015, 15 September 2017 and 29 October 2025.