J & E Davy Unlimited Company, acting as a connected exempt principal trader with recognised intermediary status, has filed a Form 38.5(a) dealing disclosure with the Irish Takeover Panel relating to Kenmare Resources plc (-KMR). The disclosure, dated 5 November 2026, covers transactions undertaken on 4 November 2026 in a client-serving capacity. The filing is made under Rule 38.5(a) of the Irish Takeover Panel Act, 1997, Takeover Rules, 2022, and is required to be made to a Regulatory Information Service for public transparency during an offer period.
Key Points
- Kenmare Resources plc (-KMR) is the offeror/offeree named in the dealing disclosure filed by J & E Davy Unlimited Company
- J & E Davy sold 13,108 ordinary shares (EUR 0.001 class) in Kenmare Resources on 4 November 2026, with no purchases recorded
- The highest price received per unit was 2.98 EUR and the lowest was 244.4 GBX, as stated in the disclosure
- Investors should watch for further Rule 38 disclosures relating to Kenmare Resources as any offer situation develops
J & E Davy Files Rule 38.5(a) Form Covering Kenmare Resources Ordinary Shares
J & E Davy Unlimited Company, an Irish financial services firm acting in a client-serving capacity, submitted its Form 38.5(a) disclosure to a Regulatory Information Service on 5 November 2026. The firm is identified in the filing as a connected exempt principal trader with recognised intermediary status, connected to Kenmare Resources plc — the named offeror or offeree in the relevant offer context. The disclosure was prepared in accordance with the Irish Takeover Panel Act, 1997, Takeover Rules, 2022, with Megan Larkin listed as the contact name on the form.
13,108 Kenmare Resources Shares Sold on 4 November 2026 at Prices Between 244.4 GBX and 2.98 EUR
The dealing section of the disclosure records a single class of transaction: the sale of 13,108 ordinary shares in Kenmare Resources plc, each carrying a nominal value of EUR 0.001. The highest price received per unit was 2.98 EUR, while the lowest price received was 244.4 GBX, reflecting dual-currency trading activity. No purchases of ordinary shares were recorded in the same period. The disclosure confirms no cash-settled derivatives, stock-settled derivatives, options, or other dealings were undertaken by the firm in relation to Kenmare Resources securities on the date in question.
No Indemnity Arrangements or Derivative Agreements Declared by J & E Davy
The filing explicitly states that no indemnity or option arrangements, and no agreements or understandings relating to options or derivatives — including those touching on voting rights or future acquisition or disposal of relevant securities — exist between J & E Davy and any party to the offer or any person acting in concert. Both sections covering such arrangements are marked not applicable, indicating the transaction was a straightforward client-serving sale with no additional structural arrangements attached, as required to be declared under the Irish Takeover Rules.
Kenmare Resources Offer Period Triggers Mandatory Transparency Obligations Under Irish Rules
Dealings by connected exempt principal traders in the securities of an offeror or offeree must be publicly disclosed under Rule 38 of the Irish Takeover Panel Act, 1997, Takeover Rules, 2022, during an active offer period. Kenmare Resources plc, a mineral sands miner, is the company in relation to whose securities these transparency obligations have been triggered. Investors monitoring the Kenmare Resources situation may note that further Form 38 disclosures from other connected parties could follow, as the rules require timely reporting of all relevant dealings for the duration of any offer period.



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