Transactions of Managers’ and their related parties

Managers’ transactions and obligation to notify transactions

Executives are required to make a corresponding written declaration of the obligation to notify the transaction related to financial instruments to their related party and to maintain a copy of that notice. Executives must notify their related parties and their transactions promptly and no later than three days of the change or the transaction. Notifications are made by email to the insider officer.

Managers and persons closely associated with them

The obligation to notify transactions applies to managers and persons closely associated with them. A person discharging managerial responsibilities is defined in Article 3.1(25) of MAR. In OmaSp a person discharging managerial responsibilities refers to a person who is

• Member of the Board of the Directors
• CEO
• CEO’s deputy
• Member of the Management Team

A person closely associated is defined in Article 3.1(26) of MAR. Persons closely associated with managers include

• a spouse, or a partner considered to be equivalent to a spouse in accordance with national law
• a dependent child, in accordance with national law
• a relative who has shared the same household for at least one year on the date of the transaction concerned
• a legal person, trust or partnership, the managerial responsibilities of which are discharged by a person discharging managerial responsibilities or by a person referred to in point a), b) or c) above or which is directly or indirectly controlled by such a person or which is set up for the benefit of such a person or the economic interests of which are substantially equivalent to those of such a person.

Notification of transactions to FIN-FSA

The transactions must be notified promptly and no later than three (3) business days after the date of the transaction. Information on transactions can be reported to FIN-FSA in two ways:

• On an electronic form, which is sent via encrypted email to FIN-FSA.
• Via XML file, which is sent via encrypted email to FIN-FSA.

The information can be submitted in Finnish, Swedish or English.

Instructions and notification form is available at:
finanssivalvonta.fi

You can find more information about the regulation related to transactions of managers’ and their related parties on the website of the Financial Supervisory Authority.

Notification of transactions to OmaSp

The transactions must be notified to OmaSp promptly and no later than one (1) business day after the date of the transaction. The transactions shall be notified to OmaSp by sending the filled FIN-FSA form by email to sisapiirivastaava.johdonilmoituksetomasp.fi (sisapiirivastaava[dot]johdonilmoitukset[at]omasp[dot]fi)

OmaSp publishes the notification it has received in a stock exchange release promptly after receipt of the notification and no later than three (3) business days after the date of the transaction.