The Raisio Group’s insider administration is organised in accordance with the Nasdaq Helsinki Ltd’s (Helsinkin Stock Exchange) Insider Guidelines (2018). Raisio plc’s Board of Directors has confirmed the insider guidelines that is based on, e.g., the following laws and official regulations: Market Abuse Regulation (MAR, EU No 596/2014) as well as regulations based on that; Securities Markets Act (746/2012, incl. amendments), Criminal Code of Finland (39/1889, incl.amendments), Act on the Financial Supervisory Authority (878/2008, incl. amendments), Current regulations and Guidelines for Insiders (2016) issued by Helsinki Stock Exchange, Guidelines of the European Securities and Markets Authority (ESMA) and Financial Supervisory Authority. Every person in the management position is informed of the insider guidelines. The guidelines are available to anyone working for Raisio plc on the company’s internal website. Raisio plc requires its management personnel and all employees to comply with insider regulations. Raisio plc’s insider administration monitors compliance with insider regulations and provides training in insider matters.
Persons acting in Raisio plc’s management positions are members of the Board of Directors and Supervisory Board, CEO and members of the Group’s Executive Committee. Persons in managerial positions and their related parties must report to Raisio and the Financial Supervisory Authority on transactions made with Raisio’s shares or other financial instruments. Raisio plc publishes the transactions as Stock Exchange Releases. Instructions for submitting the transaction notifications are here.
On its website, Raisio plc publishes up-to-date information on the shareholdings of the members of the Board of Directors (here) and Executive Committee (here) with the consent of the parties, as soon as possible after the transaction. Changes in the share-ownership are published as Stock Exchange Releases.
The Raisio Group complies with the Helsinki Stock Exchange’s Guidelines for Insiders on trading restrictions (closed window) with the following clarifications and additions: (1) A person in a managerial position (member of the Board of Directors or Supervisory Board, CEO, Group's Executive Committee member) and a person under his or her guardianship may not trade in the company’s financial instrument on their own account or for the account of a third party, directly or indirectly, (i) in the period between the end date of each reported period and the publication date of the interim , half-year financial report or the financial statement bulletin, and (ii) at any time within 30 days prior to the publication of such a financial report. (2) Persons involved with the preparation of financial reports (interim reports, half-year financial reports, financial statements bulletin) and those under his or her guardianship may not trade with the company’s financial instruments for their own account or for the account of a third party, directly or indirectly, (i) in the period between the end date of each reported period and the publication of interim report, half-year financial report or financial statements bulletin, and (ii) at any time within 30 days prior to the publication of such a financial report.
As required by the Market Abuse Regulation, Raisio plc’s insider administration maintains a register of persons in a managerial position and their closely associated persons and entities. In addition, the insider administration maintains a register of persons with access to inside information (Article 18 of MAR). As of 3 July 2016, after the Market Abuse Regulation had become into force, Raisio has not had public insiders and, in practice, all insider lists are project-specific. A person entered into a project-specific insider list is never allowed to trade in Raisio’s financial instrument for the duration of the project.
The insider administration monitors the compliance with trading restrictions concerning insiders and persons occupying managerial positions or involved in the preparation of financial reports as well as the compliance with the notification obligation. It also reviews the disclosed insider information regularly. The insider administration uses the Euroclear Finland Ltd’s book-entry system.