Insider issues
In its insider management, Summa Defence complies with the rules of the Exchange and the Market Abuse Regulation (EU) No 596/2015 (“MAR”) as well as the guidelines of the European Securities and Markets Authority. In addition, the Company complies with the Guidelines for Insiders by the Nasdaq Helsinki Ltd. The Insider Guidelines approved by the Board of Directors of Summa Defence’s company contain a summary of the company-specific principles, which, together with the Insider Guidelines of Nasdaq Helsinki Ltd, constitute the Summa Defence Insider Instructions.
Insider register
Summa Defence keeps a list of persons discharging managerial responsibilities (PDMR) as well as an extended PDMR list. An insider list is prepared when events occur where people working for the Company have access to inside information. An insider list consists of all people who have access to inside information. The list may also include non-employed persons, such as advisers.
The CEO nominates the custodian of the insider register and is responsible for communications concerning insider issues.
Closed window period
Persons discharging managerial responsibilities and persons closely related to them shall schedule the trading of Summa Defence securities so that the trading will not undermine confidence in the securities markets.
Trading by persons discharging managerial responsibilities is forbidden 30 days before the release of an interim report, a half-year report, a financial statement bulletin or any other periodically disclosed financial report.
Furthermore, trading with Summa Defence securities is forbidden always when the person in question possesses inside information related to the Company or its security, regardless of whether the person has acquired the insider information intentionally or accidentally or whether the person has been entered into the insider register or not.
Persons who become insiders due to their involvement in a project are not permitted to trade in the Company’s securities while they are project-specific insiders.
Management transactions
Managers at Summa Defence shall notify all transactions involving a reporting obligation with the securities of Summa Defence on their own behalf to the Company and to the Financial Supervisory Authority within 3 working days of the transaction. Parties related to the managers shall accordingly notify the company and the Financial Supervisory Authority within 3 working days of the transaction on their own behalf.
Transactions are reported to the Financial Supervisory Authority through an electronic transaction service at https://asiointi.finanssivalvonta.fi/en/login and delivered to the Company at ir@summadefence.com.
Summa Defence discloses the transactions made by persons discharging managerial responsibilities and persons closely associated with them without delay, however within 2 working days after the Company has been informed at the latest.
Additional information on the regulation concerning transactions by managers and persons closely associated with them is available on the Financial Supervisory Authority’s web pages: https://www.finanssivalvonta.fi/en/regulation/regulatory-framework/market-abuse-regulation/managers-transactions.