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. Category 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 Quantity column shows the size. 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 column carries the wording of the register itself.

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 Amount 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 Quantity. 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 stands in whatever currency the filing states and is never converted. American filings carry a ticker and no LEI, and the other European registers an ISIN; on this page only Dutch rows link to a company and a filer page. For the same reason Since filed is a Dutch column on this page: a price series is linked to a filing through the issuer, and this list holds that link only for the AFM register — American, German, Belgian, Swedish and Spanish rows therefore show a dash.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”.