The Insider Policy of SRV Group Plc is based on the applicable EU legislation – particularly the market abuse regulation (No 596/2014, “MAR”) and the orders and instructions issued by the European Securities and Markets Authority (“ESMA”) and other authorities under the MAR – and Finnish legislation, particularly the Securities Market Act (746/2012, amended) and the Criminal Code (39/1889, amended), and Nasdaq Helsinki Ltd ‘s Guidelines for Insiders and other guidelines, and guidelines issued by the Finnish Financial Supervisory Authority (“FSA”).
This Insider Policy describes essential rules and instructions concerning market abuse and, in particular, the prohibition on using insider information and market manipulation. The policy also describes procedures whose purpose is to enable adherence to the applicable rules and, to the extent possible, prevent the unlawful disclosure of insider information and other inappropriate conduct on the financial markets.
The public insider register (updated up to 2 July 2016) will be available, as required by the transition provision of the Securities Market Act, on SRV Group Plc’s website until 2 July 2017.
According to the provisions of the new MAR, the management of SRV Group Plc and persons closely associated with them must notify SRV Group Plc and the FSA from 3 July 2016 onwards of every business transaction they conduct on their own account involving the company’s financial instruments. The company must publish such information as a stock exchange release.
Whistle blowing procedure for reporting suspected breaches of financial market provisions and rules
SRV Group Plc has opened a confidential reporting channel (the Ethics Channel) for employees and other stakeholders who wish to report potential suspected breaches of the MAR and other related provisions and rules.
Breaches can be reported online or by post to the following address:
00210 Helsinki, Finland
Insider Administration contact information:
Johanna Metsä-Tokila, SVP, General Counsel email@example.com
Hannele von Hertzen, Senior Legal Counsel, person in charge of insider issues firstname.lastname@example.org
Satu Valkama, Executive Assistant, person in charge of insider lists email@example.com
Maija Karhusaari, SVP, Communications, firstname.lastname@example.org