dspp wrote:https://www.handbook.fca.org.uk/handbook/glossary/G2418.html
From a purely legal point of view I can't see that the OP's partner is caught by the rules.
The people covered are defined within the definition of a `personal transaction' (from the posted link):
personal transaction
a trade in a designated investment effected by or on behalf of a relevant person, where at least one of the following criteria are met:
(1) that relevant person is acting outside the scope of the activities he carried out in that capacity;
(2) the trade is carried out for the account of any of the following persons:
(a) the relevant person;
(b) the spouse or civil partner of the relevant person or any partner of that person considered by national law as equivalent to a spouse;
(c) a dependent child or stepchild of the relevant person;
(d) any other relative of the relevant person who has shared the same household as that person for at least one year on the date of the personal transaction concerned;
(e) any person with whom he has close links;
(f) a person whose relationship with the relevant person is such that the relevant person has a direct or indirect material interest in the outcome of the trade, other than a fee or commission for the execution of the trade.
She can't come within (2)(b) as she is not considered by English law to be the equivalent of a spouse.
She can't come within (2)(d) as she is not a relative.
On the face of it, I thought she might be included within (2)(e) but the definition of "close links" is only to do with ownership of a company.
And I don't see how she would come within 2(f) if the OP and his partner don't pool their finances.
However, as has been pointed out, she's not really in a position to argue the toss, and from a practical point of view she - and the OP - will probably just have to comply, no matter how irritating, or even unlawful the demand may be.