Sponda Plc’s insider administration is based on applicable Finnish and EU legislation (particularly on the Market Abuse Regulation No. 594/2014), on the orders and guidelines given by authorities and on Nasdaq Helsinki Ltd’s Guidelines for Insiders. Sponda Plc has insider and trading guidelines.
Sponda Plc’s managers and their closely associated persons have an obligation to notify Sponda Plc and the Finnish Financial Supervisory Authority of their transactions conducted relating to Sponda’s financial instruments as of 3 July 2016 according to the provisions of the Market Abuse Regulation. The company must publish such information as a stock exchange release. In Sponda Plc the members of the Board of Directors, the CEO and members of the Executive Board are included as persons having managerial responsibilities in the company.
The company maintains insider lists of persons who have access to inside information. These lists and the information contained in the lists are not public. The insider lists and the information contained in are available to the Financial Supervisory Authority. The information in the public insider register maintained by Euroclear Finland Ltd based on former legislation (updated until 2 July 2016) is available on Sponda’s website as required by the transitional provisions of the Securities Market Act.
A person discharging managerial responsibilities within the company may not execute transactions by company’s financial instruments on his or her account or for the account of a third party during a closed period of 30 days before the disclosure of the company’s financial statement release or the half-year financial report. Persons who are entered in a project-specific insider list may not trade in company’s financial instruments during the project on their account or for the account of a third party. Also persons covered by the company’s extended trading restrictions are not allowed to trade in company’s financial instruments during the closed period.