Cramo manages inside information and insiders in accordance with the requirements of the Market Abuse Regulation (MAR), the Insider Guidelines of Nasdaq Helsinki Ltd. and Cramo’s Insider Guidelines.
The Insider Guidelines of Cramo include instructions and definitions regarding inside information, trading by insiders, managers’ transactions and list of managerial persons. The coordination and control of insider affairs are included in the responsibilities of the CFO.
As of 3 July 2016, the Company is no longer obliged to maintain a public insider register. Instead, the Company maintains a list of persons discharging managerial responsibilities (Managers) and their closely associated persons. In compliance with the Market Abuse Regulation, the person discharging managerial responsibilities in Cramo Group include the members and deputy members of the Board of Directors, the President and CEO and the Chief Financial Officer (CFO). The Company also maintains project-specific insider lists when necessary.
The period, when the Managers may not trade in the Company’s financial instruments, is 30 days prior to the publication of an (quarterly) interim report and financial statement bulletin of the Company and the date of publication of such report. Project-specific insiders are prohibited from trading with financial instruments of Cramo until the termination of the project.
As from 3rd July 2016 Cramo publishes notifications by a stock exchange release on transactions conducted by persons discharging managerial responsibilities and persons closely associated with them when the transactions reach a threshold of EUR 5,000 (without netting) on a yearly level in accordance with the provisions of the MAR.