自2000年3月1日起, 电话este complies with the insider guidelines of Nasdaq Helsinki Oy in their valid form at any given time. The company also has its own insider guidelines, which have been approved by the company’s 董事会.
电话este maintains project-specific and event-specific insider lists as necessary. Project-specific insider lists include the persons who work for 电话este under an employment contract or other agreement and receive insider information concerning an individual project, as well as any other persons to whom 电话este discloses insider information concerning an individual project. ‘Project’ refers to an identifiable arrangement or set of procedures which is being prepared at 电话este in strict confidence and which, 当披露, could materially affect the value of 电话este’s financial instrument. The CEO evaluates each case to determine whether a set of procedures or an arrangement is considered as a project.
Persons discharging managerial responsibilities at 电话este with the obligation to notify are the Board members, 首席执行官, 首席财务官, the SVP in charge of the Networks business unit and the SVP in charge of the Video Security and Information business unit. They and persons closely associated with them shall notify 电话este and the Finnish Financial Supervisory Authority of any transactions they conduct in 电话este’s financial instruments. 电话este informs about transactions reported to it in a specific stock exchange release. It is recommended for persons discharging managerial responsibilities at 电话este to time their trading activities involving financial instruments issued by 电话este in such a manner that as accurate as possible information affecting the value of the share is available in the market.
The persons discharging managerial responsibilities at 电话este are not permitted, on their own account or on behalf of others, 直接或间接, to trade in financial instruments issued by 电话este during the “closed window” period, 这是, for thirty (30) days prior to the publication of an interim report and financial statement release. 电话este has expanded the closed window to also apply to persons participating in the preparation of interim reports and/or financial statement releases. Such persons are subject to the same closed window of thirty (30) days.
电话este’s insider administration supervises compliance with the insider guidelines and maintains insider lists as well as a list of persons discharging managerial responsibilities and persons closely associated with them. 电话este’s Legal Counsel is in charge of insider issues.
People employed by 电话este may report any suspected violations of rules and regulations concerning the financial markets through an independent channel within the company.