The Company complies with the guidelines for insider trading drawn up by Nasdaq Helsinki. Furthermore, the Company has drawn up separate insider trading guidelines that have been approved by the Board of Directors and that supplement other insider trading regulations as well as include instructions on insiders and insider administration.
Project-specific insider lists are drawn up of people involved in insider projects. Persons with insider information are not allowed to trade in the Company’s financial instruments until the project has become void or been published. Those entered into the project-specific list of insiders are notified of their entry and the duties it entails, as well as the termination of the list’s maintenance. Separate instructions are available for the establishment of a project-specific list of insiders.
The Company draws up a separate list of people in executive positions and their related entities. In 2018, the persons holding executive positions in the Company, as defined in the Market Abuse Regulation, were the members of the Board of Directors, the President and CEO, the Chief Financial Officer, the directors of the business areas in the Passenger Car Tyres business unit, the director of the Nokian Heavy Tyres business unit and the director of the Vianor business unit.
Persons holding executive positions within the Company are not allowed to trade in the Company’s securities for 30 days before the publication of the Company’s financial statement report, half year report, or interim report (“closed window”). The same applies to persons who participate in the preparation, drawing up, and/or publication of the Company’s financial reports. The prohibition on trading mentioned hereinabove also applies to persons who process the financial reporting and forecasts of the Nokian Tyres Group and those who have access to group-level financial figures through different systems.
The Group General Counsel for Nokian Tyres is responsible for the overall management of insider matters in the Company and the related communication (limitations on trade, obligations to announce and publish management transactions). The Group General Councel will check the information for the persons holding executive positions and their related entities at least once per year. The CFO is the Group General Counsel’s substitute for insider matters.
The Company has defined processes that relevant parties can use to notify of any violations of the Company’s insider trading guidelines or other instructions, or of any other malpractices. External parties can use the email address firstname.lastname@example.org, among others.
As of July 3, 2016 Nokian Tyres plc will publish all transactions by managers with a stock exchange release in line with the Market Abuse Regulation ((EU) No 596/2014, “MAR”).
Transactions of managers
As of July 3, 2016, managers are instructed to inform Nokian Tyres plc of their transactions on financial instruments of the company.