Insider management

Insider rules

Administer has prepared its own insider rules which include the procedures and instructions for the company’s personnel and management. The insider rules supplement the regulations and instructions included, for example, in the Market Abuse Regulation (596/2014/EU, including amendments), Nasdaq Helsinki Ltd’s rules and regulations and Financial Supervisory Authority’s currently valid insider regulations and instructions.

Administer does not maintain a list of permanent insiders. When necessary, the company maintains a project-specific insider list. People included in the insider list are not allowed to trade in the company’s securities during the validity of the project.

Executives and obligation to report transactions

According to the Market Abuse Regulation, the executives of Administer include the members of the Board of Directors, possible deputy members of the Board of Directors, CEO and members of the Management Team.

Instructions for the management’s transaction reports.

Restrictions on trading and closed trading window

Executives and their immediate circle are prohibited from carrying out transactions in the company’s securities on their own behalf or on behalf of a third party before the company has published its half-yearly report and financial statements release during the period that starts 30 days before the publication of the half-yearly report and financial statements release and ends at the time of their publication (“Closed Trading Window”). If the financial statements include relevant information that has not been previously published in the financial statements release, such as future prospects, the Closed Trading Window also applies to the financial statements.

Administer has also decided that persons involved in the preparation and drafting of the half-yearly reports and financial statements releases are prohibited from carrying out transactions with the company’s securities before the company has published its half-yearly report and financial statements release during the period that starts 30 days before the publication of the half-yearly report and financial statements release and ends at the time of their publication.

Management and supervision of insider issues

Administer’s employee in charge of insider issues, and their deputy, monitor the compliance with insider issue regulations and obligations in accordance with the instructions issued by the Financial Supervisory Authority and other authorities.

The company immediately reports any insider information abuse cases and other behaviour breaching the insider rules which it has detected on the basis of its own supervision or through other means to the Financial Supervisory Authority, which is the supervisory authority for insider issues. In addition, the company may inform the Financial Supervisory Authority of procedures contrary to the regulations and instructions of the authorities and the company’s insider rules.