Insider management

Betolar's insider management is based on insider guidelines approved by the company's Board of Directors. The guidelines describe the organisation of insider management, the practices for disclosing inside information, the management of insider lists, the obligation to report transactions and trading restrictions.

In insider matters, Betolar Plc complies with the EU Market Abuse Regulation ((EU) 596/2014 as amended, ”MAR”) and with the subordinate provisions issued pursuant thereto as well as with other applicable legislation, guidelines issued by the competent authorities and the Nasdaq Helsinki Ltd’s applicable Rulebook for Issuers of Shares and the Guidelines for Insiders.

Betolar Plc’s person in charge of insider issues is responsible for the organisation of inside information management and for monitoring compliance with MAR, insider guidelines and other insider rules in force from time to time.

The tasks of insider management include maintenance of insider lists, issuance of trading permits, notifications to senior managers and the Financial Supervisory Authority, and internal guidance and advisory.

Insider list

Betolar Plc maintains a list of persons discharging managerial responsibilities and persons closely associated with them. These persons are obliged to notify Betolar Plc and the Financial Supervisory Authority of all transactions made on their behalf in connection with the financial instruments related to Betolar Plc after the total amount of EUR 5,000 has been reached in transactions made during the calendar year. All persons discharging managerial responsibilities and persons closely associated with them are informed in writing of their position and responsibilities. Betolar Plc has the information included in the list of closely associated persons regularly reviewed with the respective persons discharging managerial responsibilities. 

Betolar Plc publishes transactions made by persons discharging managerial responsibilities and persons closely associated with them related to the financial instruments of Betolar Plc in accordance with the notifications received from them without delay and no later than within two business days of the transaction.

In addition, Betolar notifies all share rewards received by its managers within the company’s employees share savings plans.

Betolar Plc has defined the members of the Board of Directors, the CEO and the members of the Group Executive Management Team as persons discharging managerial responsibilities.

Insider List 

The Company maintains a list of persons who have access to inside information ("Insider List"). The responsibility for maintaining the Insider List is the responsibility of the Company's CFO or a person assigned by the CFO. The Company's Insider List comprises of one or more project-based insider lists.

Betolar Plc maintains a project-specific insider list of company projects that constitute inside information. A project-specific insider list is created immediately when a decision is made to establish an insider project and delay disclosure of inside information. Project-specific insider lists are created by the Board of Directors or the CEO, and are maintained by Betolar Plc’s insider management.

All persons, who have received inside information, will be listed in the project-specific insider list. A person listed on a project-specific insider list will be informed in writing of his / her entry on the list and the related obligations, prohibitions on dealing, disclosure, recommendation and inducement, sanctions and, at the end of the project, the end of the project and the termination of obligations.

Closed period

The Managers may not conduct any transactions on their own account or for the account of a third party, directly or indirectly, relating to the Company's shares or other financial instruments during a closed period of thirty (30) calendar days before the announcement of a business review, half-yearly report or a financial statement release, including the day of publication of said report or release. 

In case an annual financial report includes non-disclosed information that may have material effect, a closed period applies. The Company has elected to extend the closed period by a further two (2) days as such, that the Managers may conduct transactions no earlier than two days after the publication of said reports. 

Expanded closed period

The Company has expanded the trading restrictions during the closed period to cover also such Employees and other persons, who are not Managers, and who have a possibility to acquire information on the business review, half-yearly report or the financial statement release of the Company due to their position or duties before the publication thereof ("Closed Period Employees").

For more information on insider guidelines, please contact Betolar Plc’s person in charge of insider issues:

Riikka Ylikoski, CFO

Updated: 13.9.2023

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