Aperam S.A. (0OLF) Files Designated Person Share Transaction Notification Under EU Market Abuse Regulation

What Article 19(3) of the EU Market Abuse Regulation Requires of Aperam

The EU Market Abuse Regulation — formally Regulation (EU) No 596/2014 of the European Parliament and of the Council, adopted on 16 April 2014 — imposes strict obligations on issuers and their senior personnel to disclose transactions in the company's own financial instruments. Article 19 specifically mandates that persons discharging managerial responsibilities, as well as persons closely associated with them, must notify both the competent authority and the issuer of every transaction conducted on their own account relating to the shares or Debt instruments of the issuer. This obligation exists to ensure market transparency and to guard against the misuse of inside information.

Under Article 19(3), the issuer is required to make such notifications public promptly and no later than three Business days after the date of the transaction. Aperam's filing of this Designated Person Notification on 24 June 2026 reflects its compliance with these obligations, directing the market to the Luxembourg Stock Exchange's OAM platform — the official Officially Appointed Mechanism for the storage and dissemination of regulated information in Luxembourg — where the complete and legally prescribed details of the transaction are held. The announcement does not reproduce the specific transactional data within the EQS wire text itself; the full record is accessible only via the linked regulatory databases.

Designated Persons at Aperam: Who Is Covered by This Disclosure Framework

Under the MAR framework, a "Designated Person" in this context refers to individuals discharging managerial responsibilities within the company, which typically includes members of the Board of Directors and Executive Officers who have regular access to inside information and the authority to make managerial decisions affecting the future development and business prospects of the company. Aperam's announcement uses the phrase "Directors or Executive Officers" to describe the category of individual to whom this notification relates, consistent with standard MAR terminology.

The identity of the specific individual involved in the notified transaction, the nature of the transaction — whether a purchase, sale, or other dealing — the number of shares involved, the price per share, and the aggregate value are not reproduced in the announcement text distributed via EQS. Investors seeking these specifics are directed to the OAM database on bourse.lu or to Aperam's investor relations page at aperam.com under the "Investors > News &Amp; Contact > Managers' Transactions" section. The company did not disclose these figures in the announcement itself.

Where Investors Can Access the Full Managers' Transaction Record

Aperam has provided two primary routes for investors wishing to review the complete notification. The first is the Luxembourg Stock Exchange's electronic OAM database, accessible at www.bourse.lu, which serves as the regulated repository for all official disclosures made by Luxembourg-domiciled or Luxembourg-listed entities. The OAM platform allows any member of the public or investor to search for regulatory filings associated with a given issuer, including all historical Designated Person notifications.

The second access point is Aperam's own corporate website at www.aperam.com, specifically the Managers' Transactions subsection under the Investors and News & Contact pages. Maintaining this information on the company's own website in addition to the regulatory repository is considered best practice under MAR guidelines and allows retail investors direct access without navigating the regulatory platform. Both sources should reflect the same underlying transaction data as filed with the relevant authority.

Aperam's Business Profile and Scale as Context for Insider Transaction Significance

Understanding the scale of Aperam as an enterprise provides important context for investors assessing the potential significance of any insider transaction notification. Aperam is a global producer of stainless steel, electrical steel, and specialty steel, operating across four primary reportable business segments: Stainless & Electrical Steel, Services & Solutions, Alloys & Specialties, and Recycling & Renewables. The company serves customers in over 40 countries and operates sixteen production facilities spread across Brazil, Belgium, France, the United States, India, and China.

In the financial year 2025, Aperam reported sales of EUR 6,080 million and total shipments of 2.29 million tonnes, according to information provided within the announcement. The company has a flat stainless and electrical steel production capacity of 2.5 million tonnes across its Brazilian and European operations and positions itself as a leader in alloys and high-value specialty products. This scale means that director and officer share transactions, whilst routine compliance disclosures, may attract attention from institutional and retail investors alike given the size of the enterprise and the potential informational value attributed to insider activity.

Aperam's Sustainability and Circular Economy Positioning

The announcement includes a detailed description of Aperam's strategic commitment to sustainability and the circular economy — themes that have become increasingly central to the company's investor narrative. Aperam highlights its unique capability to produce low-carbon-footprint stainless and special steels using biomass, stainless steel scrap, and high-performance alloys scrap. The company's Bioenergia division, which produces charcoal from its own FSC-certified forestry operations, underpins this green production model for its Brazilian facilities.

Aperam Recycling, described in the announcement as a global leader in collecting, trading, processing, and recycling stainless steel scrap and high-performance alloys, further reinforces the group's circular economy credentials. These operational features are increasingly relevant to ESG-focused investors who monitor not only financial performance but also the environmental and governance characteristics of their portfolio holdings. The filing of transparent insider transaction notifications such as this one is itself a component of strong corporate governance, which forms the 'G' pillar of ESG assessment frameworks.

Regulatory Compliance Context: MAR Filings and Market Integrity

The EU Market Abuse Regulation was introduced to create a uniform and strengthened regulatory framework for market abuse across European markets, replacing the earlier Market Abuse Directive. One of its central objectives is to ensure that all participants in financial markets have access to the same information at the same time, preventing those with privileged access — such as company directors — from gaining an unfair advantage. The Designated Person Notification mechanism is a direct tool to achieve this objective by mandating public disclosure of insider dealings within a tightly defined timeframe.

For Aperam, which is domiciled in Luxembourg and subject to Luxembourg financial regulation, compliance with MAR is overseen by the relevant national competent authority. The company's proactive distribution of the notification via EQS — a widely used European financial wire service — alongside the formal filing with the OAM reflects a commitment to reaching the broadest possible investor audience with regulatory disclosures. Investors should note that the issuance of such a notification does not in itself carry any positive or negative implication; it is a mandatory transparency measure required by law regardless of the nature or direction of the transaction disclosed.

How This Notification Fits Into Aperam's Ongoing Investor Relations Programme

Aperam maintains an active investor relations function, with Roberta de Aguiar Faria identified in the announcement as the Investor Relations contact, reachable at [email protected]. Communications matters are handled separately by Ana Escobedo Conover, contactable at [email protected]. This dual-contact structure reflects a professionally managed IR and communications operation consistent with a company of Aperam's scale and international profile.

The Managers' Transactions section on Aperam's investor relations website serves as a centralised archive of all historical Designated Person notifications, allowing investors to build a longitudinal picture of director and officer dealing activity over time. Analysts and governance specialists frequently review such archives to identify patterns in insider activity, though it is important to note that individual transactions must always be interpreted within their proper regulatory context and without reading undue inference into routine compliance disclosures. Investors may be watching subsequent filings or corporate announcements from Aperam for further context on management activity.

Share Price Implications and Investor Considerations Following the Filing

The immediate share price impact of this Designated Person Notification was not clear from available public information. Designated Person notifications are regulatory filings rather than operational or financial announcements, and their market impact — if any — typically depends on the specific details of the transaction disclosed: the identity of the person involved, whether the transaction represents a purchase or disposal, the scale of the dealing relative to the individual's total holding, and the prevailing market context at the time of disclosure. None of these specifics are reproduced within the EQS announcement text.

Investors considering the materiality of this disclosure in the context of their own holdings or research into Aperam should consult the full notification as published on the OAM database at bourse.lu, where the legally required granular details of the transaction will be formally recorded. It is also worth noting that Aperam shares are subject to trading on the Euronext Brussels exchange, and the company's broader financial performance — including its 2025 revenues of EUR 6,080 million and shipment volumes of 2.29 million tonnes — remains the primary driver of medium-to-long-term Investment consideration rather than any single insider transaction filing.

EQS Group as Disseminator and the Issuer's Responsibility

The announcement was disseminated as a Financial Wire News release by EQS Group, a pan-European provider of regulatory and financial communications services used by hundreds of listed companies across the continent. EQS Group acts solely as the technical distributor of the disclosure; the announcement explicitly states that "the issuer is solely responsible for the content of this announcement," in line with standard regulatory wire protocol. This attribution of responsibility is consistent with MAR requirements, which place the obligation to notify squarely on the issuer and the individual concerned.

The use of a regulated distribution channel such as EQS ensures that the notification reaches the market simultaneously and in full compliance with the equal-access provisions embedded in MAR. For investors, this means the information should be considered publicly available from the moment of its EQS release timestamp — recorded as 24 June 2026 at 18:29 CET/CEST — and any dealings in Aperam shares undertaken after that point should be assessed in the knowledge that this disclosure has been made. The EQS reference number for the announcement is 2353238.