Insider Management

With regards to insider management, Kojamo plc complies with the provisions of Market Abuse Regulation (EU) No. 596/20147 (“MAR”) of the European Parliament and the Commission, guidelines issued by the Finnish Financial Supervisory Authority and the European Securities and Markets Authority (ESMA) as well as the rules and insider guidelines of Nasdaq Helsinki Ltd. Kojamo does not maintain a register of permanent insiders.

Kojamo has prepared insider guidelines that apply to persons discharging managerial responsibilities within Kojamo as well as to all persons who have access to inside information. At Kojamo, a person discharging managerial responsibilities refers to members of the Board of Directors, the CEO and the members of the Management Team.

Management transactions

Persons at Kojamo discharging managerial responsibilities and persons closely associated with them must inform Kojamo and the Finnish Financial Supervisory Authority of all their business transactions.

Kojamo publishes notifications on transactions made by persons discharging managerial responsibilities and persons closely associated with them promptly and no later than three business days after the date of the transaction. Instructions for reporting Management transactions can be found here.

Event-based insider lists

The insider guidelines shall be applied to any persons otherwise acting on behalf of the Company or on its account when they perform tasks through which they have access to inside information. All persons who have access to project-related inside information and who work for the Company or perform tasks for the Company through which they have access to project-related inside information, including any external consultants and auditors, are entered in the event-based insider list.

Trading restrictions

Persons subject to trading restriction include the members of the Board of Directors, the CEO, members of the Management Team and e.g. persons participating in the preparation, drawing-up and disclosure of financial reports or other persons who receive information about Kojamo’s result before it is disclosed. The trading restriction is also applied to legally incompetent persons under the custody or trusteeship of persons subject to the trading restriction. The restriction also covers the execution of transactions for one’s own account or for the account of a third party, directly or indirectly, for instance through a legal person over which a person discharging managerial responsibilities exercises control.

A person who discharges managerial responsibilities within Kojamo or who has been defined to be subject to the trading restriction may not execute transactions on their account or for the account of a third party during a closed period.

Closed period

At Kojamo, the closed period begins once the quarter in question ends and runs until the publication of a financial statements bulletin, a half-year financial report or an interim report. However, the closed period is always at least thirty (30) days before the publication of the interim report, half-year financial report or financial statements bulletin in question. Kojamo does not repurchase its own shares during this period.

In addition to closed period, Kojamo has defined a silent period in its disclosure policy, beginning 30 days prior to the publication of the following financial report. During this time, the Company’s representatives do not meet with capital market representatives or issue statements regarding the Company’s business prospects, markets, financial performance or outlook to the media or other parties.

Closed periods and silent periods are indicated in the investor calendar.

Page updated 19 June 2019