Insider Guidelines

Insider Guidelines

Insider guidelines

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.

Insider ownership

SRV has determined not to establish and maintain a list of permanent insiders but instead all persons involved will be included as project insiders for the relevant projects.

According to the provisions of the MAR, the management of SRV Group Plc (SRV Group Plc’s members of the Board of Directors, President and CEO and CFO) and persons closely associated with them must notify SRV Group Plc and the FSA 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:

BDO Oy
Forensic Services
Vattuniemenranta 2
00210 Helsinki, Finland

Insider Administration contact information:

Johanna Metsä-Tokila, SVP, General Counsel johanna.metsa-tokila@srv.fi
Hannele von Hertzen, Senior Legal Counsel, person in charge of insider issues hannele.vonhertzen@srv.fi
Satu Valkama, Executive Assistant, person in charge of insider lists satu.valkama@srv.fi
Miia Eloranta, SVP, Communications, miia.eloranta@srv.fi