The purpose of the Insider Guidelines of Sitowise Group Plc is to summarize the most important rules and procedures regarding the use and management of inside information in the company. Insider Guidelines include rules and regulations about prohibited use of inside information, the company's insider lists, disclosure and delayed disclosure of inside information and notifying transactions of the company's management and their closely associated persons.
The Insider Guidelines are based on Finnish and EU laws and regulation. The most important regulations concerning inside matters are the EU's Regulation 596/2014/EU on market abuse (the "MAR"), the Level 2 delegated regulations adopted under the MAR, standards relating to MAR issued by ESMA (European Securities and Markets Authority), the Finnish Securities Markets Act (746/2012, as amended), the Finnish Penal Code (39/1889, as amended) as well as the guidelines for insiders of Nasdaq Helsinki Oy.
In its insider guidelines and management, as well as communications, the company complies with the above-mentioned rules and regulations, the guidelines of the Finnish Financial Supervisory Authority and ESMA, and Nasdaq Helsinki Ltd’s rules. The company also complies with the Insider Guidelines and the disclosure policy approved by the company’s Board of Directors.
Regardless of the Insider Guidelines or any other instructions given by the company, everyone, including the employees and service providers, is always personally responsible for complying with the laws, regulations and guidelines concerning inside matters.
Everyone must in each case personally assess whether the information he or she possesses constitutes inside information. This obligation applies any time regardless of whether the person is entered into an insider list and regardless from whom or in which way he or she has obtained the information