Sievi Capital complies with the applicable EU Market Abuse Regulation (596/2014, ”MAR”) valid since 3.7.2016, and the insider guidelines of Nasdaq Helsinki Ltd. In addition, Sievi Capital has its own internal Insider Policy.
Sievi Capital has decided not to maintain public insiders or permanent company-specific insider register, but only project-based insider lists. Project specific lists will be established and maintained for each project constituting inside information, based on the insider guidelines of Nasdaq Helsinki and Company’s own internal guidelines.
Sievi Capital maintains an internal, non-public list on managers and persons closely associated with them. Sievi Capital has determined the members of the Board of Directors, CEO and CFO as managers defined in the Market Abuse Ragulation (MAR). Each manager and persons associated with them are obliged to disclose all transactions made with financial instruments issued by Sievi Capital. These transactions are published with a regulatory release. The total shareholding of each Manager is annually published as part of the Corporate Governance Statement according to the Corporate Governance Code of Finnish listed companies.
Sievi Capital’s above-mentioned executives, personnel, and any other persons involved in the preparation, compilation and publication of the Company’s financial reports shall not conduct the transactions related to Sievi Capital’s financial instruments within 30 calendar days prior to the company’s financial statements.