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Open Letter: Marcus Stuttard, Mr Bogus Sheriff of AIM - are Lords exempt from your rulebook?

By Tom Winnifrith, The Sheriff of AIM | Wednesday 26 October 2016

Disclosure: I have no positions in any stocks mentioned, and no plans to initiate any positions within the next 72 hours. I wrote this article myself, and it expresses my own opinions. I am not receiving compensation for it (other than from ShareProphets). I have no business relationship with any company whose stock is mentioned in this article.

Earlier today I pointed out how Lord David Evans, the senior NED at Advanced Oncotherapy (AVO) sold his entire holding of shares during a closed period and just ahead of a major placing. He appears only to have told the company this week, although the share sales took place between 19 August 2016 and 16 September 2016. This is a massive breach of AIM Rule 21. I have written to Marcus Stuttard, the head of the Oxymorons at AIM Regulation.

Re Breach of AIM Rule 21 - do your rules not apply to members of the House of Lords?

Dear Marcus.

In the corner of your office, covered in dust, is a copy of the AIM Rule Book. If you clean it up and have a butchers, you will note Rule 21:

An AIM company must ensure that its directors and applicable employees do not deal in any of its AIM securities during a close period. In addition, the purchase or early redemption by an AIM company of its AIM securities or sale of any AIM securities held as treasury shares must not be made during a close period.

The Exchange may permit a director or applicable employee of an AIM company to sell its AIM securities during a close period to alleviate severe personal hardship.


Yesterday there was an announcement relating to the senior NED at Advanced Oncotherapy, the well known industrialist Lord David Evans.

between 19 August 2016 and 16 September 2016 Lord David Evans, a Non-Executive Director of the Company, disposed of 136,296 ordinary shares of 25 pence each in the Company ("Ordinary Shares"), at a weighted average price of 121 pence per share. Following these transactions, Lord Evans no longer holds any Ordinary Shares of the Company.


Advanced announced its results and a placing on 30 September. If there was an exemption made for the Lord because he is in a financial mess then Advanced would surely have known of this waiver and thus of the share sales and so announced the share sales on 16 September.

I conclude therefore that there was no exemption applied for by Advanced and that Lord Evans has thus breached Rule 21. Surely you must demand he be fired? For case precedent I refer you to Cawkwell & Kryso Resources.

Or is it one Rule 21 for we peasants and another for members of the House of Lords?

I remain, as ever,

Your obedient servant

Tom Winnifrith
The Real Sheriff of AIM

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