Enedo applies the Guidelines for Insiders approved by NASDAQ Helsinki Oy, as well as any relevant amendments. Enedo’s Board of Directors has approved Enedo’s insider guidelines.
It is in the best interest of Enedo Plc, its shareholders and its personnel to avoid negative publicity regarding the suspected misuse of inside information. Explicit and properly followed insider guidelines enhance confidence towards Enedo in the markets. In order to avoid misuse of insider regulations Enedo has drawn up group level Insider Guidelines including guidelines e.g. on prohibition on unlawful disclosure and abuse of inside information, insider lists, notification requirements and trading restrictions. Enedo’s Board of Directors has confirmed the Insider Guidelines.
Enedo’s Insider Guidelines are binding on all employees of Enedo Group as well as members of the Management Board and the Board of Directors
The guidelines are based on the following rules and regulations:
• Market abuse regulation (EU 596/2014) (”MAR”) and statutes issued under this regulation
• The Securities Markets Act (746/2012)
• The Criminal Code of Finland (39/1889)
• Act on the Financial Supervisory Authority (878/2008)
• NASDAQ Helsinki Ltd’s (”The Exchange”) Guidelines for Insiders and Rules of the Exchange
• Guidelines by the European Securities and Markets Authority (ESMA) and the Financial Supervisory Authority (FIN-FSA)
INSIDER CONTROL AND CLOSED WINDOW
Enedo’s Financial Director is responsible for insider control. He or she ensures that insiders are aware of insider regulations and adhere to trading restrictions. Insiders are not allowed to trade Enedo Oyj securities for a period starting 30 days prior the publication of the company’s financial statement bulletin and interim reports and ending the day following the day of the release of such a report . Project-specific insiders are not allowed to trade Enedo’s securities before the project has been made public or discontinued.
INSTRUCTIONS ON NOTIFICATIONS REGARDING INFRINGEMENTS OF FINANCIAL MARKET
Persons in the service of Enedo Plc’s (”company”) may via an independent channel announce any alleged infringements of rules and regulations concerning the financial market, including acts against the guidelines for insiders of the company and of Nasdaq Helsinki Ltd. The notification shall be made in an informal letter (anonymously if one so wishes) to the Managing Director of the company.
The company ensures the protection of the author of the notification so that the author of the notification will not become a subject of discrimination or inappropriate actions. Handling of notifications is properly organised and the personal data of the person making the notification and the person as the subject of the notification shall be protected in accordance with the Personal Data Act (523/1999). The personal data of the person making the notification and the person being the subject of the notification shall be kept confidential, unless otherwise is provided in the law in relation to investigate the infringement or the right of the authority to access such information. Access to the information concerning the identity of the author of the notification or the subject of the notification as well as information regarding the content of the notification is limited solely to those persons to whom such is necessary in order to investigate the matter.
The company shall keep necessary information concerning such notification in accordance with the Securities Markets Act for a period of five years following the notification, unless further storing of the information is necessary for criminal investigations, on-going legal proceedings, regulatory investigation or for the protection of the rights of the person making the notification or the person being the subject of the notification. Any further need for continued storage shall be reviewed no later than three years after the previous revision. A record shall be made of the review.
The rights of the person being the subject of the notification are set out in the Personal Data Act. In addition what is provided in the Personal Data Act, a person registered as the subject of such information shall not, however, have right of inspection to the notified information, where the disclosure of such information could undermine the investigation of the suspected infringements