Harvia complies with the Market Abuse Regulation ((EU) No. 596/2014, “MAR”), including its amendments and regulations issued under it, the guidelines issued by the European Securities and Markets Authority (ESMA) and the Finnish Financial Supervisory Authority, and the insider guidelines of Nasdaq Helsinki Ltd. In addition, the company has supplemented Nasdaq Helsinki Ltd’s insider guidelines with its own insider guidelines.
Harvia maintains a list of employees and service providers who have access to insider information. The company’s insider list comprises one or more project-based insider lists. The company has estimated that it does not have insiders who would require a separate supplement to the insider list.
The company has appointed a person in charge of insider issues, who is responsible for maintaining insider lists, handling trading restrictions and the management of the obligation to notify and disclose transactions, internal communications related to insider issues, training on insider issues and the supervision of insider issues.
Harvia has internal procedures for publishing insider information, possible delayed disclosure of insider information, and maintaining project-specific insider lists.
Management transactions
Harvia has determined that managers, whose transactions shall be notified, include members of the Board of Directors, the CEO, and members of the Management Team, as well as persons closely associated with the aforementioned individuals. These individuals and their closely associated persons are required to notify the company and the Financial Supervisory Authority of every transaction conducted on their own account relating to the shares, debt instruments, derivatives or other financial instruments of Harvia. Harvia discloses the information via a stock exchange release without delay, at the latest within three business days following the execution of the transaction. Stock exchange releases are available in the section Releases.
Read more about the shareholdings of Harvia Plc’s management in the section Management holdings.
Trading restrictions
Harvia observes the trading ban on managers (closed window) specified in MAR article 19(11). In addition, the company has separately defined specific individuals who participate in preparing financial reports, or who have access to information related to such reports, as being restricted by a trading ban of similar length and content (closed window).
Persons with managerial responsibilities may not conduct transactions on their own account or for the account of a third party, directly or indirectly, in Harvia shares, debt instruments, or related derivatives or other financial instruments during the 30-day closed window preceding the publication of an interim report or annual financial statements.
