The Company complies with the Insider Guidelines of NASDAQ OMX Helsinki effective 9 October 2009 and it is available for review on www. nasdaqomx.com.
HKScan’s insiders are split into a public register and a company specific (non-public) register. By law, the public insiders are members of the Board of Directors, the Company’s auditors and the CEO. By corporate decision, the HKScan Management Team and designated representatives of the principal owners’ administrative bodies are the public insiders too. These number approximately 20 persons.
By corporate decision, certain managing directors of subsidiaries, members of financial and accounting clerical staff, communications officers, management secretaries, etc. – a total of approximately 40 persons – are included in the company-specific (non-public) register of permanent insiders.
TRADING PROHIBITION
HKScan’s permanent insiders may not trade in the Company's shares during 30 days before the disclosure of an interim report and financial statements bulletin (so called 'closed window').
Insiders are always prohibited from trading during 30 days before the publication of interim reports and financial statement bulletin, including the day of publication (the so called 'closed window'). During other times i.e. as of the day following the publication of interim reports and financial statement bulletin there is an open window during which permanent insiders are allowed to trade provided that they do not possess insider information at such time and that the insider has undergone a special permit procedure.
In the permit procedure an insider must always contact the person responsible for insider issues in HKScan before trading in securities issued by the company, in order to ensure that there are no obstacles for trading. Trading is only permitted after receiving a written evaluation to the effect that there are no obstacles for trading. The evaluation is valid for seven days during which the trade must be executed.
PROJECT-SPECIFIC INSIDERS
The decision to establish project-specific registers of insiders is taken by the CEO on a case by case basis. Persons entered in a project-specific register are prohibited from trading in the Company’s shares until the relevant project is announced or lapses.
CONTROL
The Company ensures compliance with insider holding guidelines
by regularly reminding insiders of permitted trading windows and by
checking the register maintained by Euroclear Finland Ltd once
a year to see the trades carried out by insiders. In the same
context, the Company sends an extract from the register to each
insider to allow him or her to check and complete their own
personal information in the register. HKScan’s Group administration
maintains and manages the insider register. The
public register resides in the SIRE system of Euroclear
Finland Ltd.
Public access to the registers has been provided
since 2005 on the Company’s website.
- See the public insider register
here.