FHDDS51525 | Penalties, sanctions and offences: penalties – policy: Trading without approval - Unprompted and prompted disclosure

A disclosure is unprompted if it is made at a time when the person making it has no reason to believe that we have discovered or are about to discover the failure.

Otherwise it is a prompted disclosure. We want to encourage unprompted disclosures.

A disclosure will be treated as unprompted even if at the time it is made the full extent of the disclosure is not known, as long as the full details are provided within a reasonable time.

There can be no halfway house between unprompted and prompted. It is either one or the other.

All the facts need to be considered before deciding if a disclosure is unprompted or prompted. You should apply a common sense approach in deciding whether or not a disclosure is unprompted and avoid making hasty judgements.