Sanoma’s Insider Policy complies with the Guidelines for Insiders issued by Nasdaq Helsinki Ltd. and other relevant legislation, such as Market Abuse Regulation.
According to the Insider Policy, a person who has gained inside information may not use the information by acquiring or disposing of Sanoma’s financial instruments (either on his own or a third party’s behalf, directly or indirectly), or give either direct or indirect advice on trading.
Sanoma has a standardised process for assessing inside information, delaying disclosure and establishing of insider lists.
- People who have access to all inside information, due to the nature of their position at Sanoma, are listed as permanent insiders. Currently, there are no permanent insiders at Sanoma.
- Deal-specific or event-based insider lists are established based on a case-by-case evaluation when inside information related to an event or deal is identified and a decision on delayed disclosure is made. Those who have been entered onto a deal-specific (or event-based) insider list are not allowed to trade Sanoma’s financial instruments until the project has been publicly disclosed or otherwise terminated.
Sanoma applies a closed period, which is a thirty (30) calendar day period, before the announcement of the Financial Statements Release, the Half-year report and the Interim Reports.
During the closed period, the members of the Board and the President and CEO shall not conduct any transactions in Sanoma’s financial instruments on their own account, or on the account of a third party, whether they possess inside information or not. Additionally, transactions are not allowed during the entire publication day. Sanoma also recommends that the EMT members and persons engaged in financial reporting do not trade in Sanoma’s financial instruments during the closed period or the publication day.
Members of the Board and EMT shall always check beforehand the appropriateness of trading with the company secretary. Members of the Board and EMT may also issue an explicit, documented trading programme, which must comply with Nasdaq Helsinki Ltd. rules and regulations on trading programmes. Sanoma may publish such trading programmes on its website. There were no trading programmes in place on 31 December 2022.
The Board members, the President and CEO and persons closely associated with them must notify Sanoma and the Finnish Financial Supervisory Authority of their transactions with Sanoma’s financial instruments (the so-called Manager’s Transactions). The notification must be done within two days of the transaction. Sanoma shall publish such a notification as a stock exchange release within three days of the transaction at the latest. A delay in giving the notification may lead to sanctions.
Sanoma publishes the notifications as a stock exchange release. Releases on managers’ transactions are available here.