The Board of Directors of Lehto Group Plc has ratified on 16 June 2016 the company’s Insider Guidelines which include directives and policies concerning insider administration, such as manager’s transactions, trading restrictions and insider’s register. The Insider Guidelines supplement the provisions of the Market Abuse Regulation (EU No 596/2014, the “MAR”) and any rules and regulations based on it, Finnish regulations, such as the Criminal Act (39/1889, as amended) and the Securities Markets Act (746/2012, as amended), as well as Nasdaq Helsinki’s Insider Guidelines effective from 3 of July 2016.
Trading of the company’s financial instruments should be scheduled in a way that it does not weaken the confidence in the securities market. Lehto Group recommends long-term investments to the company’s financial instruments. Trading should be scheduled at times when the market has the fullest knowledge of the matters affecting the value of company’s financial instruments.
Notifications of managers’ transactions
Managers under the obligation to report and their closely associated persons have the obligation to notify Lehto and Financial Supervisory Authority of every transaction conducted on their own account relating to the financial instruments of the company. These notifications shall be made of any transaction over the annual value of EUR 5,000. These notifications shall be made promptly and no later than three business days after the date of transaction (T+3). Lehto recommends that the notification shall be done promptly and no later than 24 hours following the transaction. Lehto in turn will disclose such information as a stock exchange release promptly and no later than three business days after the date of transaction, as required by MAR.
Lehto Group’s insiders
Lehto Group’s insiders are divided into two groups. Persons obliged to declare insider holdings are members of the Board (and deputies), CEO (and Deputy CEO) and other senior management of the company, who have regular access to inside information and are in the position to make decisions about the company and its future development.
Project-specific insiders are persons who have access to specified inside information. Project-specific insiders may also include persons acting on behalf of the company, such as lawyers and consultants.
The company maintains a project-specific insider’s register of any such confidential project that can be described as projects as defined by Nasdaq Helsinki and that can have a material effect on the value of the company’s financial instruments.
The company maintains a list of managers under the obligation to report and their closely associated persons.
Closed window for managers under the obligation to report
Lehto Group complies with the EU Regulation on Market Abuse (MAR), which declares that managers under the obligation to report insider holdings may not trade the company’s financial instruments during the 30 days prior to the publication of a Lehto Group half year financial report, interim reviews on financial position and development or financial statements release (so called “closed period”). In accordance with the Lehto Group’s regulation, the closed period ends the second day from the publication of a Lehto Group half year financial report, interim reviews on financial position and development or financial statements release. In addition Lehto recommends that trading with the company’s financial instruments takes place after the end of the closed window, i.e. on the 2nd to 32nd day after the release of financial information.
Company specific trading restrictions, i.e. extended closed window
According to Nasdaq Helsinki’s insider guidelines the closed window shall be applied to persons that take part in the company’s half year financial reports and financial statements and to other persons defined by the company, i.e. extended closed window.
The extended closed window implies that trading with the company’s financial instruments is prohibited of persons subject to the extended closed window in the 30 days prior to publication of quartal financial information and financial statements including information concerning the financial development of the company. These trading restrictions end on the second day following the publication of financial information. In addition Lehto recommends that trading with the company’s financial instruments takes place after the end of the closed window, i.e. on the 2nd to 32nd day after the release of financial information.
Lehto Group’s CFO is in charge of the company’s insider administration: CFO Veli-Pekka Paloranta, email@example.com, tel +358 400 944 074. The CFO appoints the person in group management responsible for maintaining the inside register.
Information about insider trading can be found here.