The Central Bank takes action against Alan Dalton for breaches of Market Abuse Regulation

The Central Bank has fined Alan Dalton for breaching the prohibition on insider dealing in the Market Abuse Regulation (MAR).

Central Bank of Ireland (the Central Bank) imposed sanctions on Mr. Alan Dalton in the total amount of €67,580 for trading on foot of inside information on two occasions, in contravention of MAR. Today’s announcement follows the settlement (PDF 139.94KB) reached between the Central Bank and Mr. Dalton on 10 November 2026.

Mr. Dalton breached MAR by engaging in insider dealing on two separate occasions, by successfully selling shares he owned in HealthBeacon PLC (the Company and his former employer) in circumstances outside of the normal exercise of his employment, profession, or duties. He sold the shares whilst in possession of price sensitive, material, inside information, relevant to the Company. Neither the Company nor any of its other employees or agents were the subject of this investigation.

Central Bank Director of Enforcement Karen O’Leary said:

“Trading while in possession of inside information, especially when an individual is in a privileged position to hold such information, is an abuse of the system and undermines the integrity of the market and as such is viewed very seriously by the Central Bank.

This outcome demonstrates the Central Bank’s willingness to investigate suspicious transaction and order reports (STORs) received from market intermediaries and follow our investigations through to the appropriate conclusion, holding those engaging in market abuse to account.

The submission of STORs under Article 16 of MAR is a key safeguard in our systems to protect securities markets from abuse. The timeliness and quality of STORs being submitted to the Central Bank is important to ensuring the Central Bank’s ability to reinforce market integrity.”

Mr. Dalton:

• Through his role, became aware of specific issues with the Company’s supply chain meaning that it would not in the short term be able to produce the Smart Sharps Bin in volumes previously advised to investors.
• Resigned and ceased working for the Company on 24 June 2022.
• On two separate occasions, 27 June 2022 and 4 July 2022, he called his broker requesting that his shares in the Company be sold.
• On 6 July 2022, the Company made an unscheduled announcement via RNS that it was experiencing unanticipated delays in the near-term supply of components for the Smart Sharps Bin reducing its deployment forecast. This announcement caused the Company’s share price to fall sharply.
• Whilst in possession of the same price sensitive inside information contained in the Company’s RNS announcement, and before that RNS announcement was made by the Company on 6 July 2022, Mr. Dalton called his broker on two separate occasions after his final working date to sell shares in the Company.
• Avoided a loss of €21,800 by selling his shares when he did.

As a result, Mr. Dalton breached Article 14(a) of MAR, prohibiting insider dealing, on two dates in 2022.

Mr. Dalton admitted the contraventions and agreed to resolve this matter with the Central Bank, resulting in overall sanctions being imposed by the Central Bank in the sum of €87,200. This figure is made up of €21,800 disgorgement and a separate monetary sanction in the amount of €65,400. Following the application of a 30% settlement discount, which under legislation is only applied to the monetary sanction, Mr. Dalton will pay a total sanction of €67,580.

In deciding the appropriate sanctions to impose, the Central Bank considered all relevant circumstances, including the need to impose a penalty proportionate to the privileged position Mr. Dalton was in, being in possession of specific information that was not in the public domain, which, when made public, had a direct negative impact on the Company’s share price. Due to his actions, Mr Dalton did not suffer this impact and avoided a financial loss.

This marks the first occasion on which the Central Bank will impose disgorgement as a sanction.

Notes to editors

Disgorgement is a distinct and separate administrative sanction to a monetary penalty, which restores market parity by reversing unjust enrichment, as opposed to a fine, which is imposed to punish an act itself.

For details on the Market Abuse Regime and regulations, please see Notes Section of the Public Statement (PDF 139.94KB).