"FCA Listing Rule Changes Applicable to Premium Listed Companies"

Skadden, Arps, Slate, Meagher & Flom LLP


On 2 October 2012, the Financial Conduct Authority (FCA) published a wide-ranging consultation paper (CP12/25) on the effectiveness of the listing regime which proposed a number of changes to the Listing Rules, including in relation to controlling shareholders, corporate governance and free float requirements.

On 5 November 2013, the FCA published a further consultation paper (CP13/15) setting out a package of near-final rules based on the FCA’s proposals in CP12/25 and further consultations on revised and new proposals resulting from feedback to CP12/25, which ended on 5 February 2014.

The package of final rules were presented to and approved by the FCA board on 1 May 2014 and the Listing Rules (Listing Regime Enhancements) Instrument 2014 (FCA 2014/33) was published on 2 May 2014. The instrument implements the new rules and comes into force on 16 May 2014. The FCA’s policy and feedback statement on the new rules are also expected to be published on 16 May 2014.

1. Independence and Control

New Eligibility Requirement and Continuing Obligation

An applicant for and companies with a premium listing must carry on an independent business as its main activity at all times, subject to an exception for closed-ended and open-ended investment funds.


The FCA has provided guidance setting out the factors that may be relevant in determining whether a premium listed company meets the independence requirement. The guidance lists factors that may indicate that an applicant is unable to carry on an independent business, including situations where:

  • a majority of the revenue generated by its business is attributable to business conducted directly or indirectly with a controlling shareholder;
  • it does not have strategic control over the commercialisation of its products or the freedom to implement its business strategy;
  • it does not have access to independent financing other than from its controlling shareholder;
  • its business consists principally of holdings of shares in entities that it does not control; or
  • a controlling shareholder appears to be able to influence the operations of the premium listed company outside its normal governance structures or via material shareholdings in one or more significant subsidiary undertakings.

Mineral Companies

Mineral companies will be exempt from the guidance which provides that an applicant may not satisfy the requirement for an independent business if its business consists primarily of holdings of shares in entities that it does not control. This is due to the fact that mineral companies will be eligible for a premium listing if they have a reasonable spread of direct non-controlled interests.

2. Controlling Shareholders

Against the prevailing backdrop of recent concerns and market developments over the protection of minority shareholders (particularly where there is a controlling shareholder), the FCA is implementing various new initial and on-going requirements which aim to ensure that a premium listed company with a controlling shareholder is capable of acting independently of its controlling shareholder and its associates.

Definition of “Controlling Shareholder” and “Associate”

The FCA has set out a revised definition of “controlling shareholder”, which retains the percentage holding test of 30%. The definition has however been amended so that a person’s interests will be aggregated with those of their concert parties. Under the revised definition, a controlling shareholder would include any person who individually or together with any of its concert parties exercises or controls 30% or more of the votes able to be cast on all or substantially all matters at the company’s general meeting (with certain voting rights being disregarded for the purposes of the calculation).

In addition, the FCA has also set out a new definition of “associate” to prevent controlling interests being split to avoid the relevant Listing Rules. An “associate”, when used in the context of a controlling shareholder who is an individual, would cover:

  • an individual’s spouse, partner or child (the “individual’s family”);
  • the trustees of any trust of which the individual or any of the individual’s family is a beneficiary;
  • any company in whose equity securities the individual or any member(s) of the individual’s family are directly or indirectly interested to be able to exercise or control the exercise of 30% or more of the votes at a general meeting or to appoint a majority of directors of the premium listed company; or
  • any partnership in which the individual or any member(s) of the individual’s family are directly or indirectly interested so that they hold or control a voting interest at least or greater than 30% of the partnership.

An “associate”, when used in the context of a controlling shareholder which is a company, would cover:

  • any company which is its subsidiary or parent undertaking or fellow subsidiary undertaking of the parent undertaking;
  • any company whose directors are accustomed to act in accordance with the controlling shareholder’s directions or instructions; or
  • any company in the capital of which the controlling shareholder and any other company above taken together, would be able to exercise or control the exercise of 30% or more of the votes at a general meeting or to appoint a majority of directors of the premium listed company.

Relationship Agreement

The FCA has also implemented the requirement that a written and legally binding agreement be entered into between a premium listed company and a controlling shareholder so as to ensure the independence of the premium listed company. Where a premium listed company has more than one controlling shareholder, it would not be necessary to enter into separate agreements with each of the controlling shareholders if the premium listed company considers, in light of its understanding of the relationship between the controlling shareholders, that one controlling shareholder can procure the compliance of the others with the independence provisions.

The overall framework for relationship agreements will include the following:

  • Content: The agreement must contain undertakings that:
  • transactions with the controlling shareholder (or its associates) are conducted at arm’s length and on normal commercial terms;
  • neither the controlling shareholder nor its associates will take any action that will prevent the premium listed company from complying with its obligations under the Listing Rules; and
  • neither the controlling shareholder nor its associates will propose or procure the proposal of a shareholder resolution which is intended or appears to be intended to circumvent the proper application of the Listing Rules.
  • Duration: The agreement must remain in place, and the independence provisions contained in it must be complied with, for so long as the premium listed company has a controlling shareholder.
  • Disclosure: The premium listed company’s annual report must include a statement by the board of directors that the company has entered into a relationship agreement, the company has complied with the mandatory independence provisions and, so far as the company is aware, the controlling shareholder and its associates have complied with the independence provisions. If this is not the case, there must be a statement confirming that the FCA has been notified of the non-compliance and a brief description of the reasons for the non-compliance to enable shareholders to evaluate the impact of the breach. The annual report must also include a statement if an independent director does not support the board of directors’ statements.

A transitional period of six months will apply for existing premium listed companies with a controlling shareholder to comply with the requirement for a relationship agreement. The same period is proposed for companies that acquire a controlling shareholder following admission.

Sanctions for Breach of Relationship Agreement

The FCA has also implemented enhanced oversight measures which would require all transactions with the relevant controlling shareholder to be subject to prior independent shareholder approval in the event that the mandatory independence provisions in the relationship agreement are breached. These measures will be triggered in the following circumstances:

  • where the premium listed company does not have a required relationship agreement in place;
  • where the premium listed company breaches the independence provisions in the relationship agreement;
  • where the premium listed company becomes aware that a controlling shareholder or any of its associates is breaching an independence provision in the relationship agreement; or
  • where any independent director disagrees with the board’s assessment of whether the obligations have been complied with.

The sanctions will remain in place until the publication of the next annual report in which the board makes a clean compliance statement without any disagreement from independent directors. During this period, none of the safe harbours in Listing Rule 11 (Related Party Transactions), including those for small transactions and ordinary course transactions, would apply in respect of transactions between the premium listed company and the controlling shareholder (effectively meaning that independent shareholders could veto any transaction between the company and the controlling shareholder, regardless of its size). This would however be subject to the FCA’s ability to dispense with or modify the sanctions in exceptional circumstances where the company is for example in severe financial difficulty.

3. Independent Directors

The FCA is implementing the requirement for a dual voting structure to apply to the appointment of independent directors. This would require any such appointments to be approved both by the shareholders as a whole and also by the independent shareholders. In the event that the results of the votes conflict, a further vote of all shareholders may take place not less than 90 days nor more than 120 days later on a simple majority basis. The guidance to the new requirement clarifies that an existing independent director who is being proposed for re-election may remain in office until the second vote.

The dual voting structure must be provided for in the company’s constitution. There is also a transitional period in place so that if the premium listed company did not previously have a controlling shareholder it will have until the date of its next annual general meeting to amend its constitution to implement the dual voting structure and to comply with such provisions.

The premium listed company will also be subject to increased disclosure requirements where it will have to disclose in any election or re-election circular any existing or previous transactions or relationships between the proposed director and the controlling shareholder or its associates. The FCA has also provided that if the premium listed company did not previously have a controlling shareholder, the additional disclosure requirements will not apply to a circular which is despatched within three months from the date of the event which made the company have a controlling shareholder.

4. Free Float Requirements

The FCA has maintained the free float requirement for both premium and standard listings at 25%. It has however included new rules and guidance relating to the calculation of the free float and when it may modify the rules to accept a free float percentage lower than 25%, which include the following:

  • Locked-up shares: In addition to the existing categories of shares that are excluded from the free float calculation for both premium and standard listings, shares subject to a lock-up period of over 180 calendar days will also be excluded.
  • Holdings of investment managers: In relation to the exclusion of holdings of 5% or more of shares from the free float calculation for both premium and standard listings, the FCA has implemented new guidance that will disaggregate the holdings of individual investment managers in the same group and treat such holdings of individual investment managers separately, provided that investment decisions are made independently by the individual in control of the individual fund and those decisions are unfettered by the group to which the investment manager belongs.
  • Modification of free float: In relation to premium listings, the FCA may modify the free float requirement to accept a percentage lower than 25% if it considers that there will be sufficient liquidity for the market to operate properly with a lower percentage. When considering modifications to the free float requirement, the question of liquidity is key and the FCA will consider specific factors set out in the guidance to the new rules which include:
  • the number and nature of the public shareholders; and
  • whether the expected market value of the shares in public hands at admission exceeds £100 million.

The FCA has indicated that it will be very reluctant to allow very small free floats in the premium segment as a matter of policy.  Derogations from the 25% free float requirement will only be granted in exceptional circumstances and the more that the free float falls below 25%, the weightier the evidence the FCA would expect to receive in order to be comfortable in granting a derogation.

In relation to standard listings, the FCA has indicated that the policy intention remains that the free float requirement should be effectively ‘directive minimum’ (i.e. reflecting the minimum standards required by EU directives instead of the super equivalent standards for the premium segment).  The FCA is therefore able to provide a greater level of flexibility to cater for a wider range of issuers and securities and will focus on the liquidity of the shares in judging the appropriate free float level.

5. Cancellation of Listing

The FCA has implemented the rule that where a premium listed company wishes to cancel its listing or transfer its listing from the premium to standard segment, it must obtain prior approval at a general meeting from a majority of at least 75% of the votes attaching to the shares voted on the resolution. If the company has a controlling shareholder, it must also obtain prior approval from a majority of the votes attaching to the shares of independent shareholders.

In the case of the cancellation of a premium listing in relation to a takeover offer, where an offeror or a controlling shareholder who is an offeror is interested in more than 50% of the voting rights of the premium listed company before the announcement of its firm intention to make a takeover offer, such offeror will need to obtain acceptances or acquire shares from independent shareholders that represent a majority of the votes held by independent shareholders in addition to reaching the 75% acceptance threshold. If the offeror has acquired or agreed to acquire more than 80% of the listed class of shares, then no further approval or acceptances by independent shareholders will be required to cancel the premium listing.

*      *      *      *

While some of the new rules reintroduce into the Listing Rules previous concepts such as the concept of the “controlling shareholder” or codify existing best practices such as having a relationship agreement in place between a company and a controlling shareholder, premium listed companies will still need to perform certain internal actions to ensure compliance with the full suite of new rules.

Items on the immediate agenda for premium listed companies include: (i) reviewing existing relationship agreements or entering into new relationship agreements with controlling shareholders to ensure that the requirement for and prescribed content of such agreements under the new rules are complied with before 16 November 2014; (ii) monitoring any potential controlling stakes in order that a relationship agreement can be put in place with the relevant holder within six months; (iii) establishing internal procedures to enable the board of directors to provide the various compliance statements in the company’s annual report and reporting any non-compliance to the FCA; and (iv) amending the company’s articles or other constitutional documents to reflect the dual voting structure for the appointment of independent directors at the company’s next annual general meeting.

The new rules also widen the scope of responsibilities of independent directors in monitoring and ensuring compliance with the rules and the overarching framework of corporate governance best practices.

Download PDF


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Skadden, Arps, Slate, Meagher & Flom LLP | Attorney Advertising

Written by:

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.