Insider Issues

PHM Group Holding Oyj complies with the EU Market Abuse Regulation ((EU) 596/2014 as amended, “MAR”) in insider issues and with the lower-lever regulation issued pursuant thereto as well as with the Finnish Securities Markets Act (746/2012 as amended, “SMA”), regulation and guidelines issued by the competent authorities, and the applicable rules for issuers of shares and the Guidelines for Insiders by Nasdaq Helsinki Ltd (the “Stock Exchange”). These are supplemented by the company’s own Insider policy, 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 company’s insider manager is Group Legal Counsel. The company’s insider manager is also responsible for maintaining the company’s insider lists and for the management of the trading restriction and the obligation to notify and disclose transactions The CFO of the company will act as a substitute for the insider manager.

Publishing of Inside Information

The company informs the public as soon as possible of inside information that concerns it. Disclosure of inside information is decided by the Board of Directors of the company or the CEO or insider manager. The company announces the inside information in a stock exchange release.

Trading restrictions

The company complies with the trading restrictions of the MAR Regulation on managers (closed window). The closed window begins 30 days prior to the publication date of the financial results. The Company will inform the managers that a closed window applies on them.

The transaction notifications

The manager and the persons closely associated with them must notify the FIN-FSA of their transactions related to the company’s financial instruments without delay and no later than within three business days of the transaction (T+3). The notifications are made using an electronic form that can be downloaded from the FIN-FSA’s website and submitted to the FIN-FSA in accordance with the instructions on the website.

For the company to be able to publish the transaction notifications received within the set timeframe, the managers and the persons closely associated with them must notify the company of their transactions in connection with the notification to the FIN-FSA. The notification is made by sending the form submitted to the FIN-FSA to the company.

The company publishes the received transaction notifications as an announcement without delay and no later than within two business days of receiving the notification from the manager or the persons closely associated with them. The company does not separately confirm the accuracy of the notifications it receives.