The company maintains an insider register of its insiders. The public insider register includes the Company’s Board of Directors, CEOs, Executive Board, and principal auditor. The insider registers are maintained by Euroclear Finland Ltd.
The insiders of the company are not allowed to engage in so-called short trade with a Company share or financial instrument whose underlying asset is the Company’s share. By the term short trade is meant a situation where the time between the acquisition and disposal of a financial instrument or correspondingly the time between disposal and acquisition is less than one (1) month. Notwithstanding the aforementioned general rule, the Company may, within the framework of the law and for a well founded reason, specify some personnel group to which the insider rules shall not apply.
The insiders of the company are not allowed to engage in trade with a Company share or financial instrument whose underlying asset is the Company’s share two (2) months before the publication of the Company’s half-yearly interim report or financial statements bulletin. It is also recommended to schedule trading as far as possible for those times when the market has the fullest possible information on matters affecting the share price. The restriction on trading does not affect auditors nor corporations over which insiders’ have influence. Circumvention of trading restrictions by trading on one’s own account in the name of related parties or other intermediaries, for example through corporations over which one has influence, is contrary to good practice and is prohibited.
The project-specific insider register is used in entities or arrangements which by their nature or size differ from the Company's normal business operations. The Company shall assess on a case-by-case basis whether an entity or arrangement shall be considered to be a project. The purpose of the project-specific insider register is to clarify the beginning of an insider relationship and to enhance processing of insider information.
The Company has informed the Company’s permanent insiders about its insider guidelines. The company has nominated an insider officer, who handles matters that fall within the scope of insider administration. The Company checks annually the information reported by permanent insiders, and also checks at least once a year the trading of permanent insiders on the basis of Euroclear Finland Ltd’s register information.