Insider management

Insider regulation

KoskiRent’s Insider Guidelines are based on the Finnish and EU laws and regulations, the most important being the EU Market Abuse Regulation (596/2014/EU, as amended, “MAR”), the Level 2 regulations issued by the European Commission under MAR, the guidelines issued by ESMA relating to MAR, the Finnish Securities Markets Act (746/2012, as amended), the Finnish Penal Code (89/1889, as amended), and the Insider Guidelines of the Exchange prepared by Nasdaq Helsinki Ltd (“Nasdaq Helsinki”). These are supplemented by the company’s own insider guidelines.

KoskiRent’s CFO is responsible for the insider guidelines, maintaining the insider list, managing insider matters within the company, responding to questions regarding the insider guidelines and other insider-related issues, as well as overseeing all other insider matters within the company.

KoskiRent discloses inside information, which directly concerns the company or its financial instruments as soon as possible. If the inside information relates to a matter under preparation or is otherwise not ready for disclosure, the company may delay the disclosure of the inside information. The Chair of the Company’s Board of Directors and the CEO each have the individual authority to decide on the delay of disclosure of inside information. The inside information will be disclosed via a stock exchange release.

The company maintains a list of employees and service providers who have access to inside information.

The company has informed all employees and insiders upon their initial inclusion on the insider list about the insider guidelines. The insider guidelines are available through the company’s internal information system.

Managers and managers’ transactions

The company has defined, in accordance with MAR, the members of the Board of Directors, the CEO, and the members of the Management Team as persons discharging managerial responsibilities. The managers and their closely associated persons are required to notify the company and the Finnish Financial Supervisory Authority of transactions conducted on their own account relating to the company’s shares, debt instruments, other financial instruments, or derivatives thereof.

The company notifies the managers in writing of their obligation to report transactions. The company also maintains a list of the managers and their closely associated persons.

The managers and their closely associated persons must submit an official notification of the transaction without delay and no later than three (3) business days after the execution of the transaction to the company and the Finnish Financial Supervisory Authority. The company is obligated to disclose the notifications by means of a stock exchange release.

The CFO is responsible for ensuring that the managers receive adequate training regarding their own and their closely associated persons’ obligation to report transactions.

Closed period

Managers are not permitted to conduct transactions, directly or indirectly, for their own account or for the account of a third party, involving the company’s financial instruments during the closed period of 30 days prior to the publication of the financial statements release or interim report, including the day of publication.