Insider
On July 3, 2016, the European Parliament and Council Regulation revamped the policy (596/2014 / EU) on market abuse (MAR) and it became immediately adopted into Swedish law. People in leadership positions (“Insiders”) are mandated to report transactions to the FSA and to the issuer. Link to the insider register: http://www.fi.se/Register/Insynsregistret/
Insider Policy
The purpose of this insider policy is to (i) serve as guidance for persons discharging managerial responsibilities, persons closely associated with persons discharging managerial responsibilities as well as persons who otherwise may possess inside information regarding the Company or any other group company and (ii) ensure that the Company complies with its obligations to prevent insider dealing and market abuse.
This insider policy shall be observed together with applicable laws and regulations, such as:
(i) the Swedish Market Abuse Penalties Act, (the ”Market Abuse Act”);
(ii) from time to time applicable regulations of the trading platform or regulated market on which the Company’s securities are admitted to trading and;
(iii) Regulation (EU) No 596/2014 of 16 April 2014 on the market abuse (the ”Market Abuse Regulation”),including its implementing measures and relevant European Securities and Market Authority “ESMA”) guidelines.
“Inside information” shall in this policy comprise information of a precise nature, which has not been made public, relating directly or indirectly to the Company or to one or more financial instruments, and which, if it were made public, would be likely to have a significant effect on the prices of those financial instruments or on the price of related financial instruments. The information shall be deemed to be of a precise nature if it is possible to draw conclusions about the potential effect on prices in relation to the circumstance on the event. The information shall be deemed to have a significant impact on prices if a reasonable investor would be likely to use such information as a part of its investment decision.
When evaluating what may constitute inside information, factors to be considered include for example:
(a) the expected extent or importance of the decision, fact or circumstance in relation to the Company’s activities as whole;
(b) the relevance of the information regarding the main determinants of the price of the Company’s financial instruments; and
(c) all other market variables that may affect the price of the financial instruments.
Following events are likely to affect the price of the Company’s financial instruments and are therefore typically deemed as inside information:
(a) discussions with institutional investors and other creditors;
(b) unexpected changes in earnings;
(c) significant deviation in financial result or financial position;
(d) partnership agreements with key partners or other agreements of major significance, including individual meetings;
(e) major account receivable losses; and
(f) market rumours and information leaks.
The Company is obliged to disclose inside information as soon as possible. Under certain circumstances, the Company can delay such disclosure.
