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The Company’s insiders include i) managers subject to the disclosure obligation, ii) core persons and iii) project-specific insiders.
The Company maintains non-public registers of its managers subject to the disclosure obligation and their related parties as well as of the persons regarded as core persons. The Company also maintains a non-public register of its project-specific insiders. The people entered into a project-specific insider register are notified of their inclusion and the related obligations in writing or by other verifiable means, such as email. Insiders must confirm receipt of the notification.
The Company’s managers who are subject to the disclosure obligation must report all transactions they make with the Company’s financial instruments to the Company and to the Financial Supervisory Authority. The disclosure obligation covers all business transactions made on their own behalf, either directly or indirectly.
Managers subject to the disclosure obligation are
The disclosure obligation also applies to the related parties of the managers. The managers who are subject to the disclosure obligation must inform their related parties of their disclosure obligation in writing.
Core persons are insiders with access to inside information who work at the Company on the basis of an employment relationship or otherwise perform duties. These persons may regularly receive market sensitive information as part of their duties or have technical access to it.
The trading restriction has been extended to cover certain core persons, such as the persons who prepare interim reports or financial statements, as well as certain persons who are responsible for finances, financial reporting or communications.
Project-specific insiders include everyone with access to inside information who works at the Company on the basis of an employment relationship or who is otherwise performing duties that provide them with access to insider information.
During the so-called closed window, the trading restriction applies to the Company’s managers who are subject to the disclosure obligation, the core persons and any legally incompetent persons whose interests they supervise, as well as the communities controlled by the aforementioned persons.
The Company’s project-specific insiders may not trade with the Company’s securities before the project has been published or ended.
The persons included in the list of insiders subject to the disclosure obligation and the list of core persons must be notified of their inclusion and the related obligations in demonstratable manner.
The Group CFO is responsible for the insider matters and performs the tasks related to insider management.
The insider lists are maintained in the SIRE system of Euroclear Finland Ltd.