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.
The members of the Board, the President and CEO, all of the members of the Company’s management team and the secretary of the Board of Directors, and the Chief Audit Executive have been defined as permanent insiders. A list of permanent insiders is maintained in the digital system of Euroclear Finland Oy. The Company’s permanent insiders are considered to be aware of all projects.
Furthermore, the Company draws up a separate list of people in executive positions and their related entities. The Company’s Board members, President and CEO, Business Unit managers, Vice President responsible for finance and control, the General Manager for Nokian Tyres Russia, the Vice President, of Sales of Passenger Car Tyres, and the Vice President of Production are considered persons in executive positions with regard to the market abuse regulation.
The Company maintains a project-specific list of insiders who have insider information concerning a specific project, including external advisors. The Company maintains a project-specific list of Corporate Governance Statement insiders either manually within the Company or in a digital system maintained by Euroclear Finland Oy.
The Company’s General Counsel is responsible for insider issues. The assistant of the Vice President responsible for finance and control is responsible for maintaining the list of insiders. The General Counsel is responsible for managing the trading limitations and the duty to declare business transactions. The Vice President responsible for finance and control acts as the deputy to both the General Counsel and the assistant as regards insider issues.
The insider representative supervises the trading and duty to declare of the permanent insiders and persons holding executive positions and their related entities. The insider representative will check the information to be declared from the persons holding executive positions and their related entities at least once per year.
Persons holding executive positions within the Company and permanent insiders 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 above also applies to persons who process the reporting and forecasts of the Nokian Tyres Group and those who have access to group-level financial figures through different systems.
Those included in the project-specific insider lists are prohibited from trading in the Company’s securities until the termination or publication of the project.
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.