In matters pertaining to inside information, Partnera complies with the applicable regulations, such as the requirements set by the Market Abuse Regulation (MAR), Nasdaq Helsinki Oy’s insider guidelines and the guidelines of the Financial Supervisory Authority. In addition, the company has drawn up its own insider guidelines, which define the procedures and guidelines for the company’s personnel and management for, among other things, the administration of inside information, maintaining insider lists, and the registration of transactions of people under the notification obligation.
CFO Jussi Lappalainen is responsible for the company’s insider management.
Inside information refers to information of a precise nature, which has not been made public and relates directly or indirectly to one or more issuers or one or more financial instruments, and which, if it were made public, would be likely to have a significant impact on the price of the financial instruments in question or on the price of related derivative financial instruments.
Project-specific insider list
Partnera keeps project-specific insider lists, which include all persons who have access to inside information and who are working for the company on the basis of an employment contract, or who otherwise perform tasks through which they have access to inside information. Project-specific insider lists are not public.
Public disclosure and delay of disclosure of inside informationThe company discloses inside information as a company announcement as soon as possible. Disclosure of inside information can be delayed in exceptional cases, provided that the immediate disclosure of the information is likely to harm the legitimate interests of the issuer, the delayed disclosure is not likely to mislead the public, and the confidentiality of the information can be ensured.
Quiet period and closed period
Partnera observes a quiet period of 30 days before the disclosure of the financial statement announcement and the half-yearly report. During this period, the company does not discuss the company’s profit or factors relating to it with capital market parties or media representatives. If some event during the quiet period requires immediate disclosure, Partnera will do so without delay, in accordance with the regulations pertaining to the disclosure obligation, and may comment on the event in question after its disclosure.
In connection with the disclosure of the company’s half-yearly report and financial statement, Partnera observes a 30-day closed period in accordance with the MAR. During this period, Partnera’s management and certain other personnel of the company and its subsidiaries who have access to the profit announcement information in its preparation phase are prohibited from conducting any transactions, directly or indirectly, on their own account or for the account of a third party, relating to Partnera’s financial instruments.
According to the Market Abuse Regulation, members of Partnera’s Board of Directors and management team, as well as persons closely associated with them, are obliged to notify Partnera and the Financial Supervisory Authority without delay of transactions made using Partnera’s financial instruments, at the latest within three working days of the transaction. Partnera will disclose the transactions in question in accordance with the notifications it receives, within two working days of receiving the notification pertaining to the transaction. The notification obligation applies when the value of the transactions of the person under the obligation exceeds EUR 5,000 within the calendar year.
Partnera is not liable for the correctness of the information provided by its management personnel or persons closely associated with them.
Instructions for reporting managers’ transactions
1. Log in to the Financial Supervisory Authority’s online service at https://asiointi.finanssivalvonta.fi.
2. In the service, select “Managers’ transactions” and fill in the form. Instructions for filling in the form can be found here.
Information required for the form
LEI code: 7437004FKDYS4W720960Share ticker symbol: PARTNE1ISIN code: FI0009009559
3. Please note that you must copy the information on the form before submitting it to the Financial Supervisory Authority in order to send the information to Partnera as well. Instructions can be found on the form.
4. Send the form information to email@example.com either by pasting the information into the body of the email or by attaching it to the email as a PDF. Please also provide a phone number at which you can be reached in case of possible questions.