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Insider administration

In its insider administration, Anora follows the Guidelines for Insiders issued by Nasdaq Helsinki complemented by the company’s own Insider Policy adopted by the Board. Anora maintains its own insider registers. The company does not have permanent insiders.

Persons in managerial positions are prohibited to conduct transactions (on their own account or for the account of a third party), directly or indirectly, in the financial instruments of the company during a closed period of 30 calendar days before the announcement of each of the quarterly financial reports or the year-end report (financial statement release). Anora applies the closed period after the end of each calendar quarter until the day after the announcement of the interim report or financial statements release, as the case may be (the ”Closed Window”). The Closed Window shall, however, always include at least 30 calendar days immediately preceding the announcement of the interim report or financial statements release, as the case may be, and the day of publication of such report. The prohibition is in force regardless of whether such a person holds any inside information at that time.

A project-specific insider register is also maintained when required by law or regulations. Project-specific insiders are prohibited from trading in the company’s securities until the termination of the project.

Persons in managerial positions (and their closely associated persons) are obligated to report transactions in the company’s financial instruments in line with applicable EU and domestic laws and regulations. The Board, the CEO and the CFO are designated as persons in a managerial position with an obligation to disclose their transactions

Manager’s Transactions

The transaction notification shall be made without any delay using the Financial Supervisory Authority (FIN-FSA) form. The notification shall include all required information as explained below.

Anora publishes the notification as a stock exchange release no later than two (2) business days after the receipt of the notification.

Instructions

1. Please fill in the transaction notification form

Before you open the form, you must save it on your computer by clicking on the right mouse button on top of the link and selecting “Save As”. Save the form here.

Information needed on the form are:

  • Anora Group Plc:s LEI code: 52990007AXNSS4PNX352

  • Anora Group Plc:s share ticker: ANORA

  • Anora Group Plc:s share ISIN code: FI4000292438

  • Notification reference: Generated automatically (no need to fill in)

2. Please send the filled form attached to an e-mail to the FIN-FSA and to Anora

  • To FIN-FSA: Within three (3) business days after the transaction has been made (T+3) as a secured e-mail. Go to securemail.bof.fi and send the form to johdonkaupat@finanssivalvonta.fi

  • To Anora: First an informal notification to the General Counsel (thomas.heinonen@anora.com) informing about the date of the transaction. The actual notification i.e. the FIN-FSA form shall be sent to insider.information@anora.com within two (2) business days after the transaction has been made (T+2).

Further information

More information about the regulations and instructions to use the FIN-FSA form can be found on the FIN-FSA website.