Insider management

Componenta Corporation complies with Market Abuse Regulation ((EU) No 596/2014, ”MAR”) and Level 2 regulation under it, the provisions of the Finnish Securities Markets Act and the Finnish Penal Code, any regulation and guidance given by the European Securities and Markets Authority (ESMA) and the Finnish Financial Supervisory Authority as well as the Guidelines for Insiders published by Nasdaq Helsinki in the form valid at any given time.

Insider guidelines

Componenta Corporation’s Board of Directors has confirmed specific insider guidelines for the Company to complement the regulation and guidelines above.

Managers’ transactions

The persons discharging managerial responsibilities in Componenta (the Board of Directors, President and CEO and the Corporate Executive Team) and the persons closely associated with them shall notify Componenta and the Financial Supervisory Authority of any transactions related to Componenta’s shares or other financial instruments made on their own account. Componenta publishes notifications it has received in accordance with the applicable legislation. Additional information on managers’ transactions is available here.

Closed window

Componenta applies a trading prohibition (closed window) which commences 30 days prior to the release of a financial report or financial statements bulletin and ends when the financial report or the financial statements bulletin is published. In that time the persons discharging managerial responsibilities in Componenta (the Board of Directors, President and CEO and the Corporate Executive Team) may not engage in transactions related to Componenta’s shares or other financial instruments. Componenta has separately appointed certain persons involved in the preparation of Componenta’s financial reports, also subject to an equivalent closed window.

Project-specific insiders

Componenta maintains a project-specific insider list of any projects and events which, if realised, are likely to have a significant effect on the value of Componenta’s shares or other financial instruments, and which have been subject to delaying of disclosure in accordance with MAR. The persons with access to inside information concerning Componenta are entered into the insider list maintained by the company immediately. The list is kept up-to-date on a continuous basis. In the event that inside information is disclosed to people outside Componenta Group (such as financial and other advisers), the company may request said parties to maintain a necessary insider list of the persons to whom the information has been disclosed.