Insider issues

The Group’s guidelines on insider administration follow the applicable Guidelines for Insiders of Listed Companies issued by Nasdaq Helsinki Oy. Rapala VMC Corporation maintains the list of persons discharging managerial responsibilities and if necessary, the permanent insider list and the project-specific insider lists in the InsiderLog service provided by Insiderlog Ab / Euronext Corporate Services subject to Rapala VMC Corporation’s Insider Officer’s decision. At the moment company does not maintain permanent insider list.

Moreover, the persons determined by Rapala VMC Corporation having authorized access to the unpublished financial result information are entered in a list (“Financial Reporting Group”) maintained in the InsiderLog service.

Persons discharging managerial responsibilities are subject to trading restrictions regarding the corporation’s securities. Person discharging managerial responsibilities shall not conduct any transactions on its own account or for the account of a third party, directly or indirectly, relating to the shares or debt instruments of Rapala VMC Corporation or to derivatives or other financial instruments linked to them during a closed period of 30 calendar days before the announcement of an interim financial report or a year-end report which Rapala VMC Corporation is obliged to make public. The trading restriction, the obligations on confidentiality and prohibition to disclose information or advice any person with respect to trade applies also to the Financial Reporting Group. Rapala VMC Corporation extends the restriction on trading to include the permanent insiders in case this kind of list is established. The project specific insiders are prohibited from trading with the securities during their participation.

The Group arranges internal communication, training and supervision of insider issues. General Counsel of Rapala VMC Corporation acts as an Insider Officer of the Group.