CapMan follows EU’s Market Abuse Regulations (“MAR”) that entered into force on 3 July 2016 and the Guidelines for Insiders issued by Nasdaq Helsinki. CapMan has supplemented the general guidelines with its own set of internal insider guidelines, which are stricter in some areas. The Group’s Compliance Officer is responsible for insider management.
CapMan ceased to maintain a permanent company-specific insider register after the MAR came into force on 3 July 2016. The information contained in the public insider register on 2 July 2016 is available upon request from the company. CapMan retains insider ownership register information 4 years from 3 of July 2017.
Notification requirements of managers and their closely associated persons
In accordance with MAR, CapMan has defined persons discharging managerial responsibilities (“Managers”) to include members of its Board of Directors and Management Group (including the CEO) and as of 3 July 2016, CapMan discloses the transactions in CapMan’s financial instruments of Managers and their closely associated persons in line with MAR to the extent the value of the transactions exceed in aggregate EUR 5,000 within a calendar year. The total shareholdings of each Manager will be published as part of the year end reporting pursuant to the Finnish Corporate Governance Code. The company maintains a non-public list of persons discharging managerial responsibilities at CapMan and their closely associated persons. The list is not public. CapMan Managers have been instructed to inform their closely associated persons regarding notifying transactions.
Project-specific insider list
CapMan maintains project-specific insider lists for the projects which may have a significant effect on the prices of the financial instruments issued by CapMan. These project-specific insider lists will be drafted and maintained in accordance with MAR and the company's internal policies following a decision to suspend the disclosure of inside information.
Trading and closed period
Managers and the employees of CapMan Group are not permitted to trade CapMan’s shares and share-based rights or other financial instruments without a pre-approval of the person responsible for insider management (the Compliance Officer). In addition, any persons holding inside information relating to CapMan may not trade in CapMan’s financial instruments.
CapMan’s Managers (as described above) or employees are not permitted to execute transactions in financial instruments issued by the company for a silent period of at least 30 calendar days prior to the publication of CapMan’s interim reports, half year financial report or financial statements bulletin. The publication dates are announced annually over a stock exchange release. CapMan’s Managers and employees have been instructed to inform their closely associated persons regarding closed periods and trading restrictions on CapMan’s financial instruments during closed period.
Monitoring and training
The Group’s compliance officer monitors adherence to insider guidelines in line with Guidelines for Insider by Nasdaq Helsinki and reminds employees of trading restrictions, maintains insider lists and arranges internal training for employees regarding insider issues and disclosure responsibilities of listed companies.