Gareth Hall, drip-fed exclusives, and the smaller-company PR underbelly
Not every "exclusive" you read in a tip sheet or trade publication arrived by accident. Some of them were placed deliberately, by someone
Not every “exclusive” you read in a tip sheet or trade publication arrived by accident. Some of them were placed deliberately, by someone who had information the market was not supposed to see yet. Understanding how that happens, and what it means for the price you pay, is one of the more useful things a private investor can know.
The Short Version
Here is the core of this post in brief:
- Selective disclosure is the practice of sharing price-sensitive information with certain journalists or tip sheets before it is formally announced to the market via RNS.
- It is most prevalent at the smaller-company end of the market, where regulation is lighter and PR firms operate with less scrutiny.
- UK law (Market Abuse Regulation, retained post-Brexit as UKMR) requires issuers to disclose inside information publicly and simultaneously, not drip it to favoured contacts first.
- Industry self-regulation through the PRCA and CIPR has limits: it covers PR practitioners but not the companies that instruct them.
- When a tip or “exclusive” appears in print ahead of an RNS announcement, the information asymmetry it represents is not a coincidence. Retail investors are at the wrong end of it.
What Selective Disclosure Actually Means
Most investors understand, at least in principle, that market-sensitive announcements must go through the Regulatory News Service before the company can discuss them publicly. That is the theory. A company sitting on positive drill results, a contract win, or a profit upgrade. Is supposed to release that information to the entire market at the same moment, giving every investor equal access at the same time.
Selective disclosure is what happens when that principle breaks down. Instead of going through the RNS first, someone connected to the company (usually via. Its PR adviser) gives a journalist, a tip-sheet editor, or a well-connected broker a heads-up in advance.
The information is real. It is just not public yet. And the people receiving it can act on it, or publish on it, before the rest of the market knows anything is coming.
This is not a theoretical edge case. It is a practice with a long history at the smaller-company end of the London market. One that the Financial Conduct Authority has repeatedly flagged in its Market Watch publications as a live and ongoing concern.
The Gareth Hall Account: How It Works in Practice
In researching The Street Smart Trader, Ian Lyall spoke to a financial PR practitioner. Named in the book as Gareth Hall, a pseudonym, who described with some candour how the rogue end of smaller-company PR actually operates.
The picture that emerges is not of dramatic wrongdoing. It is more mundane than that. A PR adviser with a long-standing relationship with a trade press journalist picks up the phone a day or two before an announcement.
Nothing is said explicitly. But the journalist is told that something is “coming” on a particular company, that it might be worth keeping an eye on the RNS wire. The journalist, who values the relationship and the flow of stories it brings, understands what is being communicated.
The result: a positive note appears in print, or online, or in a subscriber tip sheet, slightly ahead of the official announcement. The share price often moves in response. By the time the RNS drops, the early movers have already acted.
Retail investors who read the story in the normal course of events are buying. Into a price that has already partially reflected information they were the last to receive.
What makes this particularly difficult to police is the informality of it. Nothing is written down. Nothing is agreed explicitly.
It is the City’s version of a nod and a wink. Built into relationships that have existed for years and that generate mutual benefit for everyone involved except the ordinary investor on the other side of the trade.
Why Small-Caps Are the Main Hunting Ground
The practice is concentrated at the smaller end of the market for several reasons. Large FTSE 100 companies tend to have legal and compliance functions that take disclosure obligations seriously. The regulatory scrutiny they face is intense enough to make informal briefings genuinely dangerous for the individuals involved.
Smaller companies, particularly those on AIM or below, operate with fewer internal controls. Their PR advisers are often small boutique firms with close, longstanding relationships with the trade press and the tip-sheet universe. The companies themselves may not fully understand their disclosure obligations, or may be advised. By people who treat selective briefing as a normal part of the job.
The investment press covering smaller companies is also a tighter ecosystem. A handful of publications and newsletters cover the AIM market in real depth. The PR firms servicing that market know exactly who the influential editors are.
Those editors know that access depends on maintaining good relationships with the PR community. It creates the conditions in which informal pre-announcement briefings become an accepted part of the landscape.
The FCA’s surveillance function monitors unusual trading ahead of regulatory announcements and has. On occasion, called out patterns that suggest information was circulating before it was made public. But enforcement is difficult when the mechanism is a phone call with no paper trail.
The Regulatory Framework: MAR and What It Requires
The UK Market Abuse Regulation, retained after Brexit as UKMR, sets the legal standard clearly. Article 17 requires issuers to disclose inside information to the public as soon as possible. In a manner that enables fast access and complete, correct and timely assessment.
The simultaneous and equal disclosure principle is not a guideline. It is the law.
The regulation also makes it an offence to disclose inside information to any person unlawfully. The disclosure is not made in the normal exercise of employment, a profession, or duties. Selective briefing of a journalist ahead of an RNS does not fit that exception. The FCA has powers to pursue both the company and the individuals involved.
In practice, the FCA’s enforcement record on this specific type of breach is modest. Cases tend to be brought where the evidence is strong: where trading patterns are. Clearly linked to prior disclosure, where emails or messages exist, or where individuals have been more explicit than a careful operator would be. The informal, relationship-based version of selective disclosure that Gareth Hall describes is harder to prosecute, which is part of why it persists.
The FCA’s Market Watch newsletters, published periodically, have addressed the issue of issuer disclosure. Practices and the obligations of companies and their advisers on multiple occasions. Market Watch 75, for example, examined delayed disclosure and the risks of selective briefing in the context of MAR obligations. The message from the regulator is consistent, even if enforcement action at the smaller end of the market remains infrequent.
Industry Self-Regulation and Its Limits
The Public Relations and Communications Association (PRCA) and the Chartered Institute of Public Relations. (CIPR) both maintain professional codes of conduct that apply to their members. The PRCA’s Financial Communications Group specifically covers practitioners working in the financial sector, and its guidance includes obligations around the handling of price-sensitive information.
The limitations of this framework are structural. Membership of the PRCA or CIPR is voluntary for individuals and not required to operate a financial PR firm in the UK. The codes bind members but have no reach over non-members, and the remedies available for breaches are professional rather than legal. A PR adviser who falls foul of the PRCA code faces censure or expulsion from the body, not prosecution.
The companies instructing PR firms sit largely outside the self-regulatory framework altogether. An AIM-listed company that instructs its adviser to brief a journalist ahead of an. RNS may be breaking UKMR, but the self-regulatory apparatus is aimed at the PR practitioner rather than the issuer.
Responsibility, where it is taken seriously, tends to rest on the individual adviser to refuse or push back. Requires both awareness of the rules and a willingness to risk the client relationship.
A Worked Example
Consider a hypothetical AIM-listed resources company awaiting drill results from a project in which retail investors have taken meaningful positions. The results are positive. The company’s PR adviser, who has a long relationship with the editor of a well-read small-cap tip sheet.
Makes a call two days before the RNS is due. Nothing specific is said. But the tip sheet runs a note the following morning suggesting the company “looks.
Interesting ahead of upcoming news” and flagging the stock as one to watch.
A portion of the tip sheet’s subscriber base buys the stock. The price rises 8% over the day before the announcement. When the RNS drops the following morning confirming the positive results, the price rises a further 12%.
Retail investors who responded to the tip bought in at a price already inflated by the early move. The investors who bought ahead of the tip, whoever those were, captured the full gain. The tip sheet looks prescient.
The PR firm has served its client.
No single party in this chain necessarily committed a prosecutable offence, or at least none that could be easily evidenced. But the information asymmetry is real, and its costs are borne by ordinary investors. Who were simply not in the right network to know what was coming.
What This Means For You
The practical lesson is not that you should avoid tip sheets or trade publications covering smaller companies. Some of that coverage is excellent. The lesson is to develop a specific habit of caution when you see a. Strongly positive story appearing in print ahead of any formal company announcement.
Ask two questions. First, does this story contain information that would normally require an RNS? If the answer is yes (if it contains specifics about performance.
Transactions, or corporate developments), ask why it is appearing in a publication rather than on the regulatory wire. Second, has the share price already moved before the story appeared? If it has, someone else was already positioned.
None of this means you should never buy a tipped stock. It means you should price in the possibility that you are not first to the information. That the premium you are paying may already reflect something you were the last to receive.
In Plain English
Some of the “exclusives” that appear in smaller-company coverage are placed there by PR advisers who have drip-fed information ahead of an official announcement. The retail investor reading that story is at the back of the information queue, not the front. UK law requires all market-sensitive information to be disclosed to everyone at the same time.
Informal briefings are difficult to prove and relatively rarely prosecuted at the smaller end of the market. The safest assumption, when you see a story ahead of news, is that someone else already knew.
This post is adapted from The Street Smart Trader. Used with permission.
Street Smart is a series drawn from first-hand experience of the City of London, updated as each new chapter arrives.
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Disclaimer: The value of investments can go down as well as up, and you may get back less than you invest. This article is for informational and educational purposes only and does not constitute financial advice. Always do your own research and consider seeking independent advice before making any investment decision.