The insider administration of the company complies with the Market Abuse Regulation, the Guidelines for insiders issued by Nasdaq Helsinki Oy and the company’s own insider guidelines that have been approved by the Board of Directors and complement the Nasdaq Guidelines. The list of persons in managerial positions (persons under obligation to report) and their close associates, as well as project-specific insider registers, are maintained in Euroclear Finland Ltd’s SIRE system. The company maintains a register of all persons with access to financial information who participate in the preparation of the company’s financial statements and interim reports.
Trading is always prohibited when a person holds insider information concerning the company or its financial instruments. In addition, for persons holding managerial positions within the company and participating in the preparation of the company’s financial statements and interim reports, trading is prohibited during the closed period specified below, regardless of whether the person holds insider information at that time.
Those mentioned above may not trade in the public company’s securities or any related financial instruments during the 30-day closed period before the publication of the limited company’s financial report (closed period).
Persons in managerial positions
The persons holding managerial positions in the company comprise (persons under obligation to report):
- Members of the company’s Board of Directors and possible deputies
- CEO, Deputy CEO and CFO
Persons holding managerial positions in the limited company and their close associates must report all their business transactions to the limited company and the Financial Supervisory Authority. The obligation to report applies to all business transactions they have conducted of their own account and that concern the stock of the limited company in question or debt instruments or any related derivatives or other financial instruments. The obligation to report applies to any business transactions conducted on any marketplace or outside them.
The information concerning the business transactions conducted by the persons in managerial positions and the insiders closely associated to them is available on the company’s website at localhost.
The information concerning the holdings of the persons in managerial positions and their close associates are available on the company’s website at localhost. The information is also available at the Euroclear Finland Ltd premises at Urho Kekkosen katu 5 C, 00101 Helsinki.
Additional information on the company’s managers’ collective investment arrangements and commitments to subscribe to the company’s stock are available on the page CEO and the Executive Team.
Permanent, company-specific insiders
The company does not maintain a permanent, company-specific register.
Project and event-specific registers
A project-specific insider register is set up for each insider project on the basis of a separate decision. The project-specific insider register contains information on persons who have entered into a service or employment relationship with the company, as well as any representatives, stockholders and officials of an external company that holds information concerning the project and/or has access to the project-specific insider information, and/or persons who are responsible for implementing the project.
Persons participating in the preparation of the financial report
The company has specified the persons participating in the preparation of financial reports. The company maintains a register of all persons with access to financial information who participate in the preparation of the company’s financial statements and interim reports.
Managers’ holdings of shares
The company has defined members of the Board of Directors and members of the Group Executive Team (including the CEO) as persons discharging managerial responsibilities in accordance with the Market Abuse Regulation ((EU) No 596/2014). The managers’ holdings of shares are presented in the below table. The table is updated in the beginning of each month based on the shareholders’ register of the company and the notifications of managers’ transactions on the last day of the preceding month.
Board of Directors
|Person||Ownership as of 31 March 2020|
|Lapveteläinen Patrick ||10 000|
|– Holdings of Interest Parties||8 000|
 Chairman of the Board
CEO and Executive Team
|Person||Ownership as of 31 March 2020|
|Hane Siri||2 095|
|Karemo Mikko||12 301|
|Koivula Heikki||24 529|
|Olofsson Jörgen||1 144|
|Preger Victoria||2 145|
|Ruuska Jukka||82 356|
|Stråhlman Elina||2 250|
|Werner Karl-Johan||2 145|
|Ylipekkala Heikki||5 000|
|Öhlander Eleonor||2 145|