CapMan complies with the guidelines for insiders issued by NASDAQ OMX Helsinki that came into force on 19 October 2009. CapMan has supplemented the general guidelines with its own set of internal insider guidelines, which are stricter in some areas. The Group’s General Counsel is responsible for insider issues.
According to the definition of public insiders specified in the Securities Market Act, CapMan’s public insiders are the members of the Board of Directors, the CEO, the Deputy CEO, the members of the Management Group, and the Auditors including the Lead Auditor. In addition, the permanent company-specific insider register includes at least the CEO's Executive Assistant, the CFO, certain members of the Accounting team, the Monitoring team, the Communications team, Legal Counsels, Insider Assistant and IT team. The public and company-specific insider registers for CapMan are held by Euroclear Finland Ltd. Separate non-public project-specific insider registers are held for material projects as defined in insider regulations. A list of CapMan’s public insiders and their holdings of shares and stock options is updated monthly on the company’s website www.capman.com/capman-group/governance/insider-issues.
Employees belonging to the Group’s public or company-specific insider registers are not permitted to trade the company shares or stock options without the permission of the person responsible for insider issues. Trading by the personnel is completely forbidden in the fourteen-day period prior to publication of the company’s financial results.
Members of the CapMan Public Market team are not permitted to trade in securities of small and mid-cap companies listed on the Nordic Exchanges. In addition, the company’s insider instructions recommend that no other persons employed by the Group trade in securities of small and mid-cap companies listed on the Nordic Exchanges. According to the recommendations of the company’s insider instructions CapMan Group’s employees should always get a clearance from the person responsible for the insider issues for their trading with publicly listed Nordic securities.