Insider administration

In its insider administration, Netum complies with the Market Abuse Regulation ((EU) N:o 596/2014, MAR) and second-level regulations based on it, regulations of the Securities Market Act and the Criminal Code of Finland and with rules and guidelines of the Financial Supervisory Authority, European Securities and Markets Authority and Nasdaq Helsinki Oy (Helsinki Stock Exchange) such as the insider guidelines for listed companies by Helsinki Stock Exchange.

Netum’s insider guidelines contain Netum Group Plc’s instructions and procedures that complement these regulations. The company’s management and the entire personnel are personally responsible for following the company’s insider guidelines. The insider guidelines have been made available to the company’s management and to other persons whom they concern. The insider guidelines are available for the entire personnel in the company’s intranet. The company also establishes and maintains a project-specific, non-public insider list.

Netum’s management shall time the transactions with the company’s financial instruments so that they will not undermine the securities markets’ general trust. The company recommends that the management should make long-term investments in Netum’s financial instruments and that they should time their transactions to take place when the markets have as complete information as possible on circumstances affecting the value of the company’s financial instruments. Additional information on the company’s 30-day closed window is available in the Disclosure policy.

The publication dates of the half-year report and financial statements are published annually with a company announcement and on the company’s web pages.