Insider Administration

Aspocomp complies with the Market Abuse Regulation (MAR) and its implementing provisions, the legislation in force, Nasdaq Helsinki’s Guidelines for Insiders, as well as the instructions issued by the Finnish Financial Supervisory Authority and the European Securities and Markets Authority (ESMA). Aspocomp’s Insider Rules have been drawn up in compliance with the above laws and regulations, and also include company-specific clarifications. These Insider Rules have been approved by Aspocomp’s Board of Directors and are binding to all personnel. The Insider Rules have been distributed to all the company’s insiders.

The use and disclosure of inside information is prohibited. The prohibition against insider dealing and unlawful disclosure of inside information covers all natural and legal persons who have inside information, regardless of how and where they have obtained the information, when the person knows or ought to know that he or she possesses inside information.

Insider lists

The Market Abuse Regulation ((EU) N:o 596/2014, ”MAR”) entered into force on July 3, 2016. As a result of the MAR regulation, Aspocomp no longer has public insiders. Aspocomp maintains an insider list of persons who have access to inside information on the company and who work on tasks, whether on the basis of contracts or otherwise, that provide them with access to such information. The company also maintains a list of all persons in managerial positions and persons closely associated with them. Insider lists are not publicly available.

Managers´ transactions

As the public insider register was discontinued, Aspocomp’s obligation to disclose the transactions of persons in managerial positions and their closely associated persons has changed as of July 3, 2016. Persons in managerial positions and their closely associated persons are obligated to notify both the company and the Financial Supervisory Authority of any transactions on their own account in the company’s shares or debt-based instruments or related derivatives or other financial instruments. Aspocomp is obligated to disclose such a transaction no later than within three (3) working days of the date of the transaction. Published notifications of transactions by managers and their closely associated persons can be read here.

Insider control and closed window

The company ensures that all persons who have access to inside information recognize the legal and regulatory obligations related to this and are aware of applicable penalties for insider trading and illegal disclosure of inside information. A project-specific insider list is drawn up every time the company has an ongoing project.

Aspocomp’s managers are not allowed to trade Aspocomp’s securities for a period of 30 days prior to the publication of the company’s financial statement bulletin and interim reports (so-called “closed window”). Trading in the company’s financial instruments on one’s own behalf or for a third party, whether directly or indirectly, is forbidden during the closed window.

In addition, the company has set a closed window of 30 days prior to the publication of the company’s financial statement bulletin and interim reports for the individuals involved in the preparation, drafting and publication of the company’s financial reports.

Aspocomp’s financial calendar will be published annually in advance in a stock exchange release.

Project-specific insiders are not allowed to trade Aspocomp’s securities before the project has been made public or discontinued.

Instructions for reporting on infringements (whistleblowing)

All persons employed by Aspocomp may report a suspected abuse of regulations and provisions concerning the financial market, including activities in contravention of the insider guidelines of the company and Nasdaq Helsinki Oy, through an independent channel within the company (and anonymously if they wish).