Insider Trades

Every filing a company insider made about trades in their own company’s shares: to the Dutch regulator AFM (MAR art. 19), to the US Securities and Exchange Commission (Form 4), to the German regulator BaFin (MAR art. 19), to the Belgian regulator FSMA (MAR art. 19), to the Swedish regulator Finansinspektionen (MAR art. 19) and to the Spanish regulator CNMV (MAR art. 19). The date on every line is the day the filing reached the regulator, never the day of the trade — before the filing nobody could have known. The registers sit side by side and we do not merge them.

How to read this. Reported is the filing day, and it is the day we count from — see the paragraph above for why. Type is our classification of the source data; only an open-market buy is a purchase with the insider’s own money on the exchange, and borderline cases are set aside for review instead of shown. On an award the register reports a price of 0: nothing was paid, and the Value column shows the number of shares instead. A fractional number of shares (1.85, say) is the register’s own figure and not a rounding artifact. A dash (—) means the filing did not state that field — it is not a zero, and the role under Filed bycarries the wording of the register itself. An American filer who gives no title has ticked a box on Form 4 instead, and the role then shows that box: Director, Officer, 10% owner or Other.

About the six registers. The tag on every row says which regulator the filing went to: AFM · NL for the Dutch register, SEC · US for Form 4, BaFin · DE for the German one, FSMA · BE for the Belgian one, FI · SE for the Swedish one and CNMV · ES for the Spanish one. That is the source, not the country of the company. Neither the AFM nor the SEC publishes a total amount per line, so for those Value is the reported price times the reported quantity; BaFin publishes the total and no share count at all, which is why German rows show an amount but no share count. The FSMA publishes all three, so on Belgian rows the amount is the filed figure and not our multiplication — and the two need not agree, because an order filled in parts is reported at a rounded or representative price and we show what was filed. Finansinspektionen publishes a price and a quantity but no total, so a Swedish amount is the same multiplication as a Dutch one; where FI reports a nominal amount instead of a number of securities (bonds, convertible loans), we show neither a quantity nor an amount. The CNMV form lists every trade of a filing on its own line, with a price and a volume, and adds a total for the filing; we show the lines, so a Spanish amount is the same multiplication as a Dutch one. Every amount is shown in euros, converted at the European Central Bank’s reference rate of the trade date — or of the last day before it with a rate, for a weekend or a holiday — with the amount as filed in small type below it. A row without a euro amount — a currency the ECB publishes no rate for, or a trade whose rate is not in yet — shows the amount as filed, comes last when sorting by amount and never passes a minimum amount; a missing rate is filled in with a later update. American filings carry a ticker and no LEI, and the other European registers an ISIN. Since filed comes from a price series linked to the filing: through the issuer for the AFM register, and through the ISIN or the SEC company number for the others. Only Dutch rows have an index beside them: the AEX is the only one we hold, and it is not the market of the other registers.Scores and percentiles are calculated on the Dutch register alone.

The Belgian register is the smallest. The FSMA labels its transactions more finely than the other registers, and about three in five Belgian filings carry a label we will not turn into a plain fact — a share award inside a remuneration package, an instrument that is not a share, a subscription to a capital increase, a trade agreed off exchange. Those wait for human review instead of appearing as an ordinary purchase or sale. Our copy of the register starts at May 21, 2026 and is still being read backwards, so an empty Belgian month before that means “not yet read back”, not “nothing was filed”.

The Swedish register keeps its corrections. When a filer corrects a filing, Finansinspektionen publishes the correction as a new filing and keeps the old one, marked as revised or withdrawn. We show only the filing that currently stands, so a correction is never counted twice. FI does not check filings before publishing them. Until 2018 it did not record whether a trade was in shares or in options, warrants or bonds, so Swedish purchases and sales from 2016 to 2018 wait for review instead of appearing as an ordinary purchase or sale; so do filings without a valid ISIN, trades off exchange and trades inside a share program.

The Spanish register is read from the form itself. The CNMV publishes every filing as the standard EU notification form, in a PDF, and we read the trades from that form line by line. A filing that amends an earlier one (Modificación) waits for review, because the form does not say which filing it replaces. So do trades the form files as Otros — an inheritance, free shares, a share loan — which are explained only in free text, trades outside a trading venue, instruments other than shares and lines without a valid ISIN. The CNMV register starts on April 24, 2018 and we read it newest first, so an empty older month can mean “not yet read” rather than “nothing was filed”.

New to these filings? Read What is a MAR Article 19 notification or How to read an SEC Form 4.