Insider management

image description

Harvia complies with the Market Abuse Regulation ((EU) No. 596/2014, with it’s alterations “MAR-asetus”) and regulations issued under it, guidelines of Nasdaq Helsinki Ltd. In addition, the company has supplemented these with it’s own insider guidelines.

The company maintains a list of employees and service providers who have access to inside information. The company’s insider list comprises of one or more project-based insider lists. The company has estimated it doesn’t have permanent insiders that would require a separate supplement to the insider list.

Harvia has determined that the management, whose transactions shall be notified, construes the members of the Board of Directors, the CEO and members of the Leadership Team. These persons and their closely associated persons are required to notify the company and the Financial Supervisory Authority of every transaction conducted on their own account relating to the shares, debt instruments, derivatives or other financial Instruments of Harvia. Harvia discloses the information via stock exchange release.

The managers may not conduct any transactions on their own account or for the account of a third party, directly or indirectly, relating to the company’s shares, debt instruments, derivatives or other financial instruments during a closed period of thirty (30) calendar days before the announcement of an interim financial report, half year report or a year-end report, including the day of publication of said report.

Management transactions

Harvia has determined that managers, whose transactions shall be notified, includes members of the Board of Directors, the CEO, and members of the Management Team. These persons and their closely associated persons are required to notify the company and the Financial Supervisory Authority of every transaction conducted on their own account relating to the shares, debt instruments, derivatives or other financial Instruments of Harvia. Harvia discloses the information via a stock exchange release without delay, at the latest within three business days following the execution of the transaction.

Managers may not conduct any transactions on their own account or for the account of a third party, directly or indirectly, relating to Harvia’s shares, debt instruments, derivatives or other financial instruments during a closed period of thirty (30) calendar days before the publication of an interim financial report, half-year report or year-end report.

Trading restrictions

Harvia observes the trading ban on managers (closed window) specified in MAR article 19(11). In addition, the company has separately defined specific individuals who participate in preparing financial reports, or who have access to information related to such reports, as being restricted by a trading ban of similar length and content (closed window).