Corporate governance > Insider issues
Revenio Group Corporation complies with the rules and guidelines issued by Nasdaq Helsinki Ltd, including its Guidelines for Insiders; the Market Abuse Regulation ((EU) No. 596/2014, MAR); the provisions of the Securities Markets Act and the Criminal Code; as well as the rules and guidelines of the Financial Supervisory Authority and the European Securities and Markets Authority (ESMA). These are supplemented by the Company’s own Guidelines for Insiders, which is 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.
Revenio is to disclose any insider information that directly concerns the Company as soon as possible. The Company may delay the disclosure of insider information if all of the conditions stipulated by the applicable regulations for the delay of the disclosure of insider information are met. The Company is to publish and store all insider information that it has disclosed on its website for at least five years.
Revenio is to maintain project-specific insider registers in circumstances stipulated by the applicable regulations. These insider registers are not public, but the information in them is at the disposal of the Financial Supervisory Authority. Those participating in projects involving insiders may not, during the project, trade in shares, debt instruments, related derivatives, or other financial instruments issued by the Company.
Revenio’s related parties consist of persons holding managerial positions in the Company as well as their closely associated persons, who all have an obligation to notify the Financial Supervisory Authority and the Company of any transactions they have conducted on their own account involving the Company’s shares, debt instruments, related derivatives, or other financial instruments. In addition to the members of the Board of Directors and CEO, the members of the Group Leadership Team constitute persons discharging managerial responsibilities at Revenio Group Corporation.
Persons discharging managerial responsibilities are to make the aforementioned notification without delay and no later than within three (3) working days of the transaction. The Company is to disclose information on the transactions of persons holding managerial positions and their closely related parties without delay and no later than within two (2) working days of the received notification. Such disclosure is to be made in a stock exchange release in a manner that corresponds to the disclosure of insider information, using the release class “Manager’s transactions.” A stock exchange release on disclosed information concerning manager’s transactions is available on the Company’s website for at least five years from the publication of the release.
Members of management and other persons specifically defined by the Company may not acquire or dispose of securities issued by the Company, or any securities or derivatives entitling to said securities, during the 30 days prior to the publication of an interim report and financial statements. These publication dates are announced annually in advance in a stock exchange release.
Group Management is to supervise compliance with the Guidelines for Insiders and to maintain the necessary registers. Persons marked in the registers are to be regularly sent an extract of the information entered into the registers. Their adherence to the restrictions on trading is also to be monitored, and the related guidelines are to be provided.
The Company's CFO is responsible for insider issues. The CFO is responsible for the implementation of the following tasks in the Company, for example:
internal communications regarding insider issues;
training in insider issues;
the preparation and maintenance of insider lists and their delivery to the Financial Supervisory Authority upon request;
obtaining approvals from persons on the insider list;
supervision of insider issues;
monitoring regulatory changes concerning insider issues.
Transactions by the management
According to the regulation, the notifications shall be made to Revenio Group Corporation and the FIN-FSA promptly and no later than three business days after the date of the transaction (T+3).
Taking into account Revenio’s obligation to publish the information in question, Revenio recommends that unofficial notification shall be made to Revenio on the day of the transaction and the official notification no later than two business days after the transaction (T+2).
Instructions for filling the transaction notification form as of January 13, 2022
1. Transactions will be notified via electronic services. You can log in to the electronic services at https://asiointi.finanssivalvonta.fi/
Service-specific instructions for using electronic services can be found here.
Information needed on the form:
LEI code 743700I27E0FWSXLKK04
ISIN code FI0009010912
Notification reference Generated automatically (no need to fill in)
2. Please send the filled form attached to an e-mail as instructed below
Do not send the form by post because of the short time frame.
Send the form attached to an e-mail to robin.pulkkinen(at)revenio.fi
Revenio Group Corporation publishes the notification it has received in a stock exchange release promptly after receipt of the notification.
As of July 3, 2016, published notifications of transactions by managers and their closely associated persons can be read from stock exchange releases.
Further information on the regulation concerning the notifications of managers’ and their closely associated persons’ transactions is available at, for example, http://www.finanssivalvonta.fi/fi/Saantely/Saantelyhankkeet/mar/19_artikla/Pages/Default.aspx.