Insiders

Taaleri Plc observes the stock exchange insider guidelines published by Nasdaq Helsinki Ltd in 2016. Taaleri Plc’s Board of Directors has approved the insider and trading regulations that determine the operating practices concerning the management of insider information and trading observed in the Taaleri Group.

Organisation

At Taaleri Plc, the organisation of insider information management is the responsibility of the Group’s Head of Legal. In addition to the Head of Legal, Taaleri’s Group Compliance Officer and the keeper of the insider register are also involved in insider management. Insider management is responsible for overseeing compliance with insider and trading guidelines, the Market Abuse Regulation (MAR) and other insider regulations issued. These include the maintenance of insider registers, the granting of trading licences, notifications to the management and to the Financial Supervisory Authority, as well as training and guidance.

Persons belonging to management

Taaleri Plc keeps a list of persons working in management functions and the persons in their immediate circles. These persons are obliged to inform Taaleri Plc and the Financial Supervisory Authority about all transactions made on their account using financial instruments of Taaleri Plc. All persons working in management functions and persons in their immediate circles are informed in writing about their position and obligations. Taaleri Plc regularly asks persons working in management functions to review the information in the insider register.

Based on its management structure, Taaleri Plc considers that the persons working in management functions are members of the Board of Directors of Taaleri Plc, the CEO, the deputy CEO, members of the Executive Management Team and the Auditor in Charge.

Insider registers

Taaleri Plc does not keep a register of permanent insiders. Persons involved in insider projects are entered in project-specific insider registers. A project-specific insider register is established when a decision on the launch of an insider project and a delay to the publication of insider information has been made. Project-specific insider registers are established and maintained by Taaleri Plc’s insider management. Persons entered in a project-specific insider register are informed in writing about their entry in the register, about their related obligations and consequences and, at the conclusion of the project, about ending the project and terminating their obligations. A person entered in a project-specific insider register may not trade in the financial instruments of Taaleri Plc.

Trading restrictions and recommendations

Taaleri Plc recommends that persons in its employment schedule trading as far as possible at those times when the market has the fullest possible information on matters affecting the value of the financial instrument. A person in the employment of Taaleri Group must always seek permission to trade in Taaleri Plc’s financial instruments from Taaleri Plc’s insider management.

Neither a person in the employment of Taaleri Group nor anyone in his/her immediate circles is permitted to trade in financial instruments issued by Taaleri Plc or in financial instruments whose underlying asset is a financial instrument issued by Taaleri Plc after the end of the reporting period about which Taaleri Plc publishes a half-year report or a financial statements bulletin (“closed period”). This closed period therefore begins on 1 January and 1 July and ends upon publication of the half-year report or annual result.

Neither a person in the employment of Taaleri Group nor someone in his/her immediate circles (someone legally incompetent whose trustee is a person employed by Taaleri Group and controlled corporations of a person employed by Taaleri Group or the above-mentioned legally incompetent person) is permitted to engage in so-called short trade in financial instruments issued by Taaleri Plc or financial instruments whose underlying asset is a financial instrument issued by Taaleri Plc. Short trade means a transaction in which the time between the acquisition and disposal of the financial instrument, or correspondingly between the disposal and acquisition, is less than one (1) month.