Per Section 15 a, Securities Trading Act, individuals in executive positions at publicly traded companies must disclose to the respective company and to the Federal Financial Supervisory Authority (BaFin) transactions in that company's shares or in instruments based on the shares, including in particular derivatives.
This disclosure obligation applies accordingly to Executive and Supervisory Board members and to other company managers with regular access to insider information who are authorised to take business decisions of material importance.
The disclosure obligation also applies to individuals in a close relationship to a company manager, and to juristic persons for which the manager or related party holds an executive position or over which he/she exercises control.