Fiskars’ Insider Policy, approved by the Board of Directors, outlines the policy related to trading in Fiskars shares by all employees, executives and directors. Fiskars’ Insider Policy is based on applicable EU regulation, especially the Market Abuse Regulation (596/2014, “MAR”), and any regulation and guidance given by the European Securities Markets Authority or otherwise under MAR, and Finnish legislation, especially the Securities Markets Act (746/2012, as amended) and the Finnish Penal Code (39/1889, as amended), as well as the insider and other guidelines of Nasdaq Helsinki Ltd, and the guidance by the Finnish Financial Supervisory Authority (“FIN-FSA”).
Fiskars’ Managers, as defined by MAR, include the members of the Board of Directors and the CEO, deputy to the CEO, the CFO and other senior executives, as may be determined by the CEO from time to time. Managers and their closely associated persons are required to notify Fiskars and the FIN-FSA of every transaction conducted on their own account relating to the financial instruments of Fiskars. These notifications shall be made promptly and no later than three business days after the date of transaction (T+3). Fiskars in turn will disclose such information as a stock exchange release, as required by MAR.
As of July 3, 2016, Fiskars has not maintained a list of permanent insiders but instead all persons involved will be included as project insiders for the relevant projects. Project specific lists will be established and maintained for each project or event constituting inside information, based on a decision taken separately.
Preparation of periodic disclosure (interim reports, financial statement bulletin) or regular access to unpublished financial information is not regarded as an insider project. However, due to the sensitive nature of the unpublished information on the company’s financial results, the persons determined by Fiskars having (based on their position or access rights) authorized access to the unpublished financial result information are entered in a list of Financial Information Recipients.
Fiskars applies a trading restriction (a “closed period”) of 30 calendar days before the release of each of the quarterly financial reports and the year-end report and the day of publication of such report. The closed period applies to Managers and to the Financial Information Recipients.
For transparency, Fiskars provides on its website up-to-date information on the shareholding of the Managers, their controlled entities and their managed entities (not controlled, but substantially equivalent economic interests), subject to consent of the relevant person. Holdings and transactions in Fiskars shares by Fiskars’ Managers and closely associated persons are detailed on the Management’s Transactions page on the Company’s website.
Updated February 20, 2018