Group employees must comply with the insider regulation based on the EU’s Market Abuse Regulation (MAR) and national legislation, as well as the company’s insider guidelines based on the Nasdaq Helsinki Oy’s insider guidelines. In addition to these, the Group’s insider administration complies with the First North marketplace’s rules on insider regulation and the Financial Supervisory Authority’s orders and instructions.
The Company maintains project-specific insider lists for individual insider information, listing those individuals who have access to the same insider information. The term project refers to confidential, identifiable set of measures or an arrangement prepared by the Company, which in the Company’s view is inside information, and the disclosure of which the Company has decided to postpone in accordance with its information policy. The company assesses, on a case-by-case basis, whether the prepared case or arrangement should be considered a project.
Project-specific insiders are persons who are involved in the preparation of a project or who are aware of a project considered confidential which, if carried out, could affect the value of the security. Into the list of projects are recorded those persons who, on the basis of a work or other agreement, receive inside information about the project, as well as other persons to whom the Company provides inside information about the identified project (such as the Company’s advisors, authorities and the unlisted company that is the counterparty to the transaction).
Insider lists are not public. However, information from insider lists is available to the Financial Supervisory Authority for supervision of securities markets.
Persons in management positions within the Company and persons involved in the preparation of financial reports subject to regular reporting obligations may not, for their own account or on behalf of a third party, carry out transactions with SkartaNYAB’s securities during the period commencing 30 days before the publication of each half-yearly financial report, financial statement release or preliminary information thereof and ending on the day following the publication of such information. Persons recorded in the project list are prohibited from trading in the company’s securities until the project expires or is made public.
Trading by a person in management position or another person subject to a trading restriction during a closed window may be permitted in certain situations by decision of the Board of Directors. The prohibition of the misuse of inside information applies when deviating from the trade restriction.
List of persons in management positions and their related parties
The Company maintains a list of persons in management positions and their related parties.
A person in a management position refers to a person who is a Member (and a possible deputy member) of the Board of Directors of the Company, the CEO, the Deputy CEO, or a member of the Management Team.
A person related to a person in management position refers to:
- a spouse, civil-union partner or common-law partner
- a dependent child of a person in management position
- a relative who has lived in the same household for at least one year (at the time of the transaction); and
- a legal person, a trust or a partnership, the managerial functions of which are exercised or controlled (directly or indirectly) by, or for the benefit of, a person referred to in paragraphs 1, 2 or 3, or whose financial interests are substantially the same as those of such a person.
Persons in management positions and their related parties must report all transactions with the Company’s securities to the Company and the Finnish Financial Supervisory Authority. The notification must be made without delay, at the latest three (3) working days after the transaction has been completed. The reporting obligation shall start when the total amount of unsettled transactions has reached the threshold of EUR 5,000 in a calendar year.
The Company publishes the transactions carried out by persons in management positions and their related parties on their own account by means of a company release within two (2) working days of the receiving of the person’s notification.
The Group’s insider management is centralised with the Group’s parent company, SkartaNYAB Plc. The company’s person in charge of insider issues is the company’s Director of Investor Relations.