In insider matters, Remedy Entertainment Plc complies with the laws of Finland, more specifically the Securities Markets Act and the Criminal Code as well as Regulation (EU) No. 596/2014 of the European Parliament and of the Council on market abuse (hereinafter referred to as the “MAR”), its complementary rules and regulations and the insider guidelines of Nasdaq Helsinki Ltd (hereinafter referred to as the “Helsinki Stock Exchange”). Furthermore the company also has its own insider guidelines approved by the Board of Directors.
With the entry into force of Regulation (EU) No 596/2014 (“MAR”) of the European Parliament and of the Council on market abuse on July 3, 2016, the company does not maintain a public insider register.
Insiders and insider list
The Company is obligated to prepare and maintain a list of all persons who have access to inside information and who work for the Company under an employment contract or who otherwise perform tasks through which they have access to inside information (such as counsels, accountants and credit rating agencies).
The MAR does not separate permanent insiders and project-specific insiders. The maintenance of a separate register concerning permanent insider is subject to the company’s decision. The company has decided to draw up a register for permanent insiders. As a result, the company’s insiders can be divided into two groups: permanent insiders and project-specific insiders.
The company’s permanent insiders include:
- ordinary and deputy members of the Company’s Board of Directors
- Managing Director and
- members of the Executive Board
The project-specific insiders are persons who have access to inside information about a specific project.
The permanent insiders of the company may not trade or directly or indirectly execute transactions relating to the company’s financial instruments for their own account or for the account of a third party during the period that begins 30 days before the publication of each financial statement bulletin and half-yearly report and ends upon the publication of the financial statements or a half-yearly report (closed window).
The MAR obligates the managers of the company, who are permanent insiders, and persons closely associated with them to notify to the Company and the Financial Supervisory Authority of the transactions conducted with the company’s financial instruments. Hence, the persons closely associated with the managers have an independent obligation to notify of transactions to the Company and the Financial Supervisory Authority. The Company has prepared a list of all persons discharging managerial responsibilities and of persons closely associated with them.
Remedy publishes such transactions by a company release no later than three (3) business days of the transaction.