The Surveillance department of Nasdaq Copenhagen is responsible for supervising issuers and member firms with regards to compliance with exchange regulation. The relevant sets of rules that issuers and member firms are obliged to comply with are published on Nasdaq Copenhagen’s website.
An investigation will be initiated if the Surveillance department finds that an issuer or a member firm may have violated one or several provisions of the relevant rules.
The Surveillance department will seek to identify the possible violation and ask the issuer or member firm to explain its actions. In some cases more information is needed and the Surveillance department may contact the issuer or member firm several times and ask for further information and relevant material.
A copy of all correspondence and documentation between the Surveillance department and the issuer or the member firm may be forwarded to the Danish Financial Supervisory Authority in accordance with the rules laid down in the Danish Securities Trading Act.
In order for an investigation to be sufficiently documented, any correspondence will as a rule be conducted in Danish and in writing. That does not prevent physical meetings to take place with the participation of representatives of the issuer or the member firm and the exchange. Nasdaq Copenhagen may call upon such meetings, but will also, to the extent that it would not cause undue delay for the processing of the matter, be accessible for the party that is subject to the matter, should it wish to call upon a meeting.
If the investigation leads to the conclusion that no violation of the rules has taken place or that a violation has been insignificant, the matter can be finalized with either a remark or without further measures.
If the conclusion is that a violation of rules has taken place, but that it is of minor importance, a non-public reprimand can be issued.
In more severe cases where the issuer or the member firm is considered to have violated the rules of the exchange a proceeding involving the Nasdaq Copenhagen Disciplinary Committee is initiated. This type of proceedings against issuers or member firms is typically initiated where the sanction is likely to be in the form of a reprimand as a minimum.