Insider management

In addition to applicable legislation and authorities’ regulations, Siili complies with the guidelines for insiders issued by the Helsinki Stock Exchange. The Company’s insider guideline adopted by the Board of Directors describes and details the Company’s insider management practices. The Company’s legal director is in charge of insider issues and insider management within the Company.

The Company maintains a permanent insider list. In addition, Siili maintains a project-specific insider list of projects constituting inside information. Each person receiving inside information pertaining to a project is recorded in the project-specific insider list. Persons included in an insider list are notified in writing about their inclusion in the insider list, related obligations and the consequences of insider dealing and unlawful disclosure of inside information.

At Siili, managers within the meaning of the Market Abuse Regulation (MAR) include the members of the Board of Directors, the CEO and the rest of the management team (Managers). Managers and their closely associated persons must notify to Siili and the FIN-FSA of any transactions on Siili’s shares, debt instruments or derivatives or other financial instruments related to them without delay and at the latest three (3) days after the execution of the transaction.

At Siili, Managers and certain personnel participating in the preparation of financial reporting or receiving information on its content before publication may not trade in securities issued by the Company or conduct certain other transactions related to the Company’s financial instruments in the 30 days preceding the publication of the Company’s half-yearly report, financial statements or the Q1 and Q3 business reviews (so-called closed window). The closed window ends at the closing of the publication date.