Annex 1
Letter to Mr Simon Brickles,
Regulator Manager, AIM, from Mr J Wilson Carswell OBE
STANFORD ROOK PLC ("the Company")
Thank you for your letter of 28 April 1998.
I appreciate the efforts that you have made.
However, I strongly disagree with your suggestion that this is
a private matter and not a public matter.
I feel that the data on clinical trials that
Stanford Rook provided in their prospectus and offer documents
was both inadequate and misleading. AIM's unwillingness to ensure
that this does not happen in the future is unacceptable.
As I see it the key issue is the quality of
data of clinical trials provided in public documents by biotechnology
companies. Investors wanting to buy shares in a new bank or financial
company would expect accurate and detailed financial data, and
those thinking of buying new mining shares would expect accurate
data on recent assays (such as example is seen on page 20 of today's
Financial Times, in which quite detailed information is given
of a possible new goldmine in Mali, which appears to have used
independent methodology to reach its estimates). Likewise investors
in a new biotechnology company should receive relevant data on
key clinical trials.
This data might include facts such as:
— Place and date of trials;
— persons carrying out trials;
— status of trials ie Phase 1, 11 or
111;
— number of subjects in trials;
— statistical evaluation of trial results;
— persons carrying out statistical
evaluations;
— significant side effects of therapeutic
agents; and
— copies of published results where
available.
There are probably other criteria that could
be included. Moreover these criteria need not conflict with commercial
concerns including confidentiality.
The basic facts regarding previous clinical
trials were clearly not included in the published prospectus and
offer documents of Stanford Rook. Their absence may have lead
investors to make an inappropriate evaluation of the company.
It is probably too late for regulatory changes
to affect Stanford Rook or its investors.
However, I feel that it is the duty of regulators
to regulate. The absence by AIM of either
1. a specific company-related public response,
or
2. the issueing of guidelines on clinical
trials for use in future published biotechnology company documents,
suggests that AIM is unwilling to carry out
its regulatory function with respect to biotechnology companies.
I would appreciate your further comments.
4 May 1998
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