Due to cautionary considerations, Det norske has included all employees in the inside lists and prohibited all employees from trading in the company’s financial instruments from the point in time when the drill bit is positioned above the prognosticated reservoir and until the results have been disclosed to the market. The company has pursued this approach in order to achieve what the company deems to be the main objective of the regulations of the Securities Trading Act – prevention of insider trading.
In the discussions with the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime and the Financial Supervisory Authority of Norway, it has been ascertained that these authorities are of the opinion that Det norske has entered too many in their inside lists – and prematurely. Det norske does not concur with this interpretation of the Act, but has still decided to accept the NOK one million fine.
As a consequence of the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime’s interpretation of the keeping of inside lists and the Securities Trading Act’s stipulations concerning immediate disclosure of inside information, Det norske has decided to change its practice. In the future, Det norske will inform the market immediately when inside information occurs as a direct consequence of data registered during exploration drilling. In this way we can comply with the interpretation of the Act made by Økokrim.
Information will as a result be published earlier than before. Information that is published to the market at an earlier point will, however, be subject to reassessments as the company or the partnership analyze the data in more detail. The reason why Det norske has not implemented this practice earlier is that the data are preliminary and may be interpreted in many different ways. Det norske would like to make the market participants aware of this change of practice.
In Norway, the Norwegian Petroleum Directorate was responsible for disclosing the results from exploration and appraisal wells to the market up until 2009. This practice ensured the license partnership sufficient time for discussing and agreeing on how the results from the drilling should be disclosed, and for quality assurance of the assessments.
This practice was altered after the issue of Stock Exchange Circular 9/2009. Pursuant to this Circular, oil companies no longer have the option of postponed publication of the results of exploration wells. The companies can consequently not wait until the Norwegian Petroleum Directorate discloses the results of the drilling operations. Till now, Det norske has complied with these new regulations by disclosing the results of the drilling when these can be ascertained with a reasonable degree of certainty. From today, the market will be informed about results from exploration wells as soon as they are available.