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Relx PLC Director's Dealing 2025

Feb 18, 2025

5248_dirs_2025-02-18_7a7f6067-91c2-472f-9cd4-6178630c7665.html

Director's Dealing

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National Storage Mechanism | Additional information

RNS Number : 5938X

RELX PLC

18 February 2025

Director/ PDMR Shareholdings

Following the completion of the transactions set out in this announcement:

(a)        Erik Engstrom, Chief Executive Officer holds 1,200,251 RELX PLC Ordinary Shares/ ADRs (1,175,520 PLC Ordinary Shares/ADRs held before these transactions); and

(b)        Nick Luff, Chief Financial Officer, holds 289,260 RELX PLC Ordinary Shares (286,267 RELX PLC Ordinary Shares held before these transactions).

RELX PLC

1 Details of the person discharging managerial responsibilities / person closely associated
a) Name Erik Engstrom
2 Reason for the notification
a) Position/status PDMR
b) Initial notification /Amendment Initial Notification
3 Details of the issuer, emission allowance market participant, auction platform, auctioneer or auction monitor
a) Name RELX PLC
b) LEI 549300WSX3VBUFFJOO66
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Grant of a conditional award over Ordinary Shares under the RELX PLC Long Term Incentive Plan 2023.  There is no price payable on the grant or vesting of the award. Vesting is subject to the achievement of performance conditions over a three-year period.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 156,110
d) Aggregated information
- Aggregated volume 156,110
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Award of deferred Ordinary Shares under the Annual Incentive Plan. There is no price payable on the award or release of the deferred Ordinary Shares.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 27,631
d) Aggregated information
- Aggregated volume 27,631
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Ordinary Shares acquired following vesting of conditional share awards under the RELX Group plc Long Term Incentive Plan 2013 ('LTIP Awards'.)
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 252,024
d) Aggregated information
- Aggregated volume 252,024
- Price Nil
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Ordinary Shares acquired following release of Annual Incentive Plan deferred share awards.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 49,912
d) Aggregated information
- Aggregated volume 49,912
- Price Nil
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary Shares to meet personal tax and social security obligations arising from vesting of LTIP Awards and release of Annual Incentive Plan deferred Ordinary Shares.  The Ordinary Shares sold to meet these obligations were sold to the RELX Group Employee Benefit Trust in off-market transactions at a price of £40.73 per Ordinary Share, being the closing price on the London Stock Exchange on the date of sale.
c) Price(s) and volume(s)
Price(s) Volume(s)
£40.73 128,798
d) Aggregated information
- Aggregated volume 128,798
- Price £40.73
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument American Depositary Receipts in RELX PLC ('ADRs').

Each ADR represents one Ordinary Shares in RELX PLC of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: US7595301083
b) Nature of the transaction Sale of ADRs
c) Price(s) and volume(s)
Price(s) Volume(s)
$51.290939 26,500
$51.151159 2,157
d) Aggregated information
- Aggregated volume 28,657
- Price $51.280418
e) Date of the transaction 2025-02-14
f) Place of the transaction New York Stock Exchange
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary Shares
c) Price(s) and volume(s)
Price(s) Volume(s)
£40.33439 60,000
d) Aggregated information
- Aggregated volume 60,000
- Price £40.33439
e) Date of the transaction 2025-02-17
f) Place of the transaction London Stock Exchange
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary Shares
c) Price(s) and volume(s)
Price(s) Volume(s)
£40.555862 32,479
£40.603716 7,521
d) Aggregated information
- Aggregated volume 40,000
- Price £40.564860
e) Date of the transaction 2025-02-18
f) Place of the transaction London Stock Exchange
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument American Depositary Receipts in RELX PLC ('ADRs')

Each ADR represents one Ordinary Shares in RELX PLC of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: US7595301083
b) Nature of the transaction Sale of ADRs
c) Price(s) and volume(s)
Price(s) Volume(s)
$51.068145 11,683
$50.900984 8,067
d) Aggregated information
- Aggregated volume 19,750
- Price $50.999867
e) Date of the transaction 2025-02-18
f) Place of the transaction New York Stock Exchange
1 Details of the person discharging managerial responsibilities / person closely associated
a) Name Nick Luff
2 Reason for the notification
a) Position/status PDMR
b) Initial notification /Amendment Initial Notification
3 Details of the issuer, emission allowance market participant, auction platform, auctioneer or auction monitor
a) Name RELX PLC
b) LEI 549300WSX3VBUFFJOO66
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Grant of a conditional award over Ordinary Shares under the RELX PLC Long Term Incentive Plan 2023.  There is no price payable on the grant or vesting of the award. Vesting is subject to the achievement of performance conditions over a three-year period.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 76,607
d) Aggregated information
- Aggregated volume 76,607
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Award of deferred Ordinary Shares under the Annual Incentive Plan. There is no price payable on the award or release of the deferred Ordinary Shares.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 16,271
d) Aggregated information
- Aggregated volume 16,271
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Ordinary Shares acquired following vesting of conditional share awards under the RELX Group plc Long Term Incentive Plan 2013 ('LTIP Awards')
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 123,674
d) Aggregated information
- Aggregated volume 123,674
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Ordinary Shares acquired following release of Annual Incentive Plan deferred share awards.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 29,391
d) Aggregated information
- Aggregated volume 29,391
- Price Nil
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary Shares to meet personal tax and social security obligations arising from vesting of LTIP Awards an d release of Annual Incentive Plan deferred Ordinary Shares.  The Ordinary Shares sold to meet these obligations were sold to the RELX Group Employee Benefit Trust in off-market transactions at a price of £40.73 per Ordinary Share, being the closing price on the London Stock Exchange on the date of sale.
c) Price(s) and volume(s)
Price(s) Volume(s)
£40.73 71,941
d) Aggregated information
- Aggregated volume 71,941
- Price £40.73
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary shares
c) Price(s) and volume(s)
Price(s) Volume(s)
£40.788072 20,000
d) Aggregated information
- Aggregated volume 20,000
- Price £40.778072
e) Date of the transaction 2025-02-14
f) Place of the transaction London Stock Exchange
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary shares
c) Price(s) and volume(s)
Price(s) Volume(s)
€48.888276 15,569
d) Aggregated information
- Aggregated volume 15,569
- Price €48.888276
e) Date of the transaction 2025-02-14
f) Place of the transaction Euronext Amsterdam Stock Exchange
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary shares
c) Price(s) and volume(s)
Price(s) Volume(s)
€48.678086 18,153
€48.604239 13,032
€48.469345 11,377
d) Aggregated information
- Aggregated volume 42,562
- Price €48.599678
e) Date of the transaction 2025-02-17
f) Place of the transaction Euronext Amsterdam Stock Exchange
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Exercise of an option over Ordinary Shares under the RELX Group plc Executive Share Option Scheme 2013. The option price payable was £12.55 per share.
c) Price(s) and volume(s)
Price(s) Volume(s)
£12.55 47,778
d) Aggregated information
- Aggregated volume 47,778
- Price £12.55
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary Shares acquired on exercise of option, including shares sold to fund exercise price and to meet personal tax and social security obligations.
c) Price(s) and volume(s)
Price(s) Volume(s)
£40.885692 47,778
d) Aggregated information
- Aggregated volume 47,778
- Price £40.885692
e) Date of the transaction 2025-02-14
f) Place of the transaction London Stock Exchange
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Exercise of an option over Ordinary Shares under the RELX Group plc Executive Share Option Scheme 2013. The option price payable was €15.285 per share.
c) Price(s) and volume(s)
Price(s) Volume(s)
€15.285 50,586
d) Aggregated information
- Aggregated volume 50,586
- Price €15.285
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary Shares acquired on exercise of option, including shares sold to fund exercise price and to meet personal tax and social security obligations.
c) Price(s) and volume(s)
Price(s) Volume(s)
€49.247076 50,586
d) Aggregated information
- Aggregated volume 50,586
- Price €49.247076
e) Date of the transaction 2025-02-14
f) Place of the transaction Euronext Amsterdam Stock Exchange
1 Details of the person discharging managerial responsibilities / person closely associated
a) Name Henry Udow
2 Reason for the notification
a) Position/status PDMR
b) Initial notification /Amendment Initial Notification
3 Details of the issuer, emission allowance market participant, auction platform, auctioneer or auction monitor
a) Name RELX PLC
b) LEI 549300WSX3VBUFFJOO66
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Grant of a conditional award over Ordinary Shares under the RELX PLC Long Term Incentive Plan 2023.  There is no price payable on the grant or vesting of the award. Vesting is subject to the achievement of performance conditions over a three-year period.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 38,075
d) Aggregated information
- Aggregated volume 38,075
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Award of deferred Ordinary Shares under the Annual Incentive Plan. There is no price payable on the award or release of the deferred Ordinary Shares.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 8,266
d) Aggregated information
- Aggregated volume 8,266
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Ordinary Shares acquired following vesting of conditional share awards under the RELX Group plc Long Term Incentive Plan 2013 ('LTIP Awards')
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 61,468
d) Aggregated information
- Aggregated volume 61,468
- Price Nil
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Ordinary Shares acquired following release of Annual Incentive Plan deferred share awards.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 15,215
d) Aggregated information
- Aggregated volume 15,215
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary Shares to meet personal tax and social security obligations arising from vesting of LTIP Awards an d release of Annual Incentive Plan deferred Ordinary Shares.  The Ordinary Shares sold to meet these obligations were sold to the RELX Group Employee Benefit Trust in off-market transactions at a price of £40.73 per Ordinary Share, being the closing price on the London Stock Exchange on the date of sale.
c) Price(s) and volume(s)
Price(s) Volume(s)
£40.73 35,086
d) Aggregated information
- Aggregated volume 35,086
- Price £40.73
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
a) Name Rosemary Thomson
2 Reason for the notification
a) Position/status PDMR
b) Initial notification /Amendment Initial Notification
3 Details of the issuer, emission allowance market participant, auction platform, auctioneer or auction monitor
a) Name RELX PLC
b) LEI 549300WSX3VBUFFJOO66
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Grant of a conditional award over Ordinary Shares under the RELX PLC Long Term Incentive Plan 2023.  There is no price payable on the grant or vesting of the award. Vesting is subject to the achievement of performance conditions over a three-year period.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 23,795
d) Aggregated information
- Aggregated volume 23,795
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Award of deferred Ordinary Shares under the Annual Incentive Plan. There is no price payable on the award or release of the deferred Ordinary Shares.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 5,876
d) Aggregated information
- Aggregated volume 5,876
- Price Nil
e) Date of the transaction 2025-02-17
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Ordinary Shares acquired following vesting of conditional share awards under the RELX Group plc Long Term Incentive Plan 2013 ('LTIP Awards.')
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 38,414
d) Aggregated information
- Aggregated volume 38,414
- Price Nil
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Ordinary Shares acquired following release of Annual Incentive Plan deferred share awards.
c) Price(s) and volume(s)
Price(s) Volume(s)
Nil 10,660
d) Aggregated information
- Aggregated volume 10,660
- Price Nil
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue
4 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a) Description of the financial instrument, type of instrument Ordinary Shares of 14 51/116p each ('Ordinary Shares')
Identification code ISIN: GB00B2B0DG97
b) Nature of the transaction Sale of Ordinary Shares to meet personal tax and social security obligations arising from vesting of LTIP Awards.   The Ordinary Shares sold to meet these obligations were sold to the RELX Group Employee Benefit Trust in off-market transactions at a price of £40.73 per Ordinary Share, being the closing price on the London Stock Exchange on the date of sale.
c) Price(s) and volume(s)
Price(s) Volume(s)
£40.73 23,066
d) Aggregated information
- Aggregated volume 23,066
- Price £40.73
e) Date of the transaction 2025-02-14
f) Place of the transaction Outside of a trading venue

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