When are disposal restrictions lifted?
The genuine disposal restrictions are lifted on the first date on which an employee has an opportunity to dispose of their ESS interests. This will be the first time an employee can take some action to realise the benefit. It does not matter whether or not they chose to do so.
An example of this is trading windows. The disposal restrictions are lifted during certain periods (trading windows), allowing the shares to be traded. At the end of each trading window, the disposal restrictions are put back in place.
We consider that the disposal restrictions are lifted at the start of the first trading window in which the employee has an opportunity to trade their shares.
If the employee does not trade their shares during the first available trading window and the shares then become restricted again, this does not change the fact that the disposal restrictions were lifted.