Insider Management

Componenta’s Insider Guideline is available on the company’s internet and intranet pages. Componenta complies with the Guidelines for Insiders published by Nasdaq Helsinki in the form valid at any given time, complemented with the specifications applicable to Componenta Corporation, confirmed by Componenta’s Board of Directors. The company’s specifications include provisions on the determination of the persons discharging managerial responsibilities in the company and on the establishment of trading restrictions. Componenta, furthermore, has internal procedures in place for the projects referred to in the Insider Guideline.
 
The company’s insider management is in charge of the following tasks:
• company internal communication of insider issues;
• the provision of training in insider issues with the company;
• receiving notifications concerning persons discharging managerial responsibilities;
• the preparation and maintenance of project-specific registers;
• monitoring insider issues (including the whistleblowing system).

The person responsible for insider issues in the company is its General Counsel.

Insider management provides advice and training on insider issues as necessary.

The persons with access to inside information concerning Componenta are entered into the insider list maintained by the company immediately. The list is kept up-to-date on a continuous basis. In the event that inside information is disclosed to people outside Componenta Group (such as financial and other advisers), the company may request said parties to maintain a necessary insider list of the persons to whom the information has been disclosed.

A person with access to inside information may not disclose the inside information to outsiders, trade or engage in transactions with Componenta’s financial instruments or advise others in relation to the aforementioned.

In accordance with the applicable legislation, the persons discharging managerial responsibilities in Componenta (the Board of Directors, President and CEO and the Corporate Executive Team) and the persons closely associated with them notify Componenta and the Financial Supervisory Authority of any trading and other transactions related to Componenta’s shares or debt instruments or related derivatives or other financial instruments made on their own account no later than within three days of the transaction. Componenta makes public disclosures on the aforementioned trading and transactions in accordance with the applicable legislation.

The persons discharging managerial responsibilities in Componenta (the Board of Directors, President and CEO and the Corporate Executive Team) may not, on their own account or for a third party, directly or indirectly, engage in trading and other transactions related to Componenta’s shares or debt instruments or related derivatives or other financial instruments (closed window). The period in question commences 30 days prior to the release of financial statements or an interim report, and ends when the financial statements or interim report is published.

Componenta has separately appointed certain persons involved in the preparation of Componenta’s financial reports, also subject to an equivalent closed window.