Insider Administration

Delete Group complies with the rules and guidelines issued by Nasdaq Helsinki Ltd, including its Guidelines for Insiders; the Market Abuse Regulation ((EU) No. 596/2014, MAR); the provisions of the Securities Market Act and the Criminal Code; as well as the rules and guidelines of the Financial Supervisory Authority and the European Securities and Markets Authority (ESMA). These are supplemented by the company’s own Guidelines for Insiders,

which are designed to provide clear instructions and rules for the management of insider issues, the disclosure of insider information, the maintenance of insider lists, and the transactions of management and their closely related parties. The Guidelines for Insiders have been informed to all company employees.

Delete is to disclose any insider information that directly concerns the company as soon as possible. The company may delay the disclosure of insider information if all of the conditions stipulated by the applicable regulations for the delay of the disclosure of insider information are met. Delete is to maintain project-specific insider registers in circumstances stipulated by the applicable regulations.

The company’s General Counsel is responsible for insider issues. The General Counsel is responsible for the implementation of the following tasks in the company, for example:

  • internal communications regarding insider issues;
  • training in insider issues;
  • the preparation and maintenance of insider lists and their delivery to the Financial Supervisory Authority;
  • obtaining approvals from persons on the insider list;
  • supervision of insider issues, and
  • monitoring regulatory changes concerning insider issues

Delete’s managers and their closely associated persons have an obligation to notify the Group and the Finnish Financial Supervisory Authority of their transactions conducted relating to Delete’s shares or other financial instruments as of 3 July 2016 according to the provisions of the Market Abuse Regulation. The company publishes such information as a stock exchange release. The members of the Board of Directors, the CEO and the members of the Management team are included as persons having managerial responsibilities in the company (managers subject to the notification obligation).

The company maintains project insider lists of persons who have access to inside information. These lists and the information contained in the lists are not public. The insider lists and the information contained therein are available to the Financial Supervisory Authority. The information in the public insider register maintained by Euroclear Finland Ltd (updated until 2 July 2016) is available on Delete’s website as required by the transitional provisions of the Securities Market Act.

Managers subject to the notification obligation and persons separately defined by the company cannot acquire or dispose of securities issued by the company, or any securities or derivatives entitling to said securities, during the 30 days prior to the publication of an interim report and financial statements. These publication dates are announced annually in advance in a stock exchange release. In addition, those participating in projects involving insiders may not, during the project, trade in securities or derivatives issued by the company.

Group Management is to supervise compliance with the Guidelines for Insiders and maintain the company’s insider registers in cooperation with Euroclear Finland Ltd. The company’s managers subject to the notification obligation are to be regularly sent an extract of the information entered into the register of managers’ subject to the notification obligation. Their adherence to the restrictions on trading is to be monitored, and the related guidelines are to be provided.