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 Market 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 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 Guidelines for Insiders have been distributed to all insiders.
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.
In accordance with MAR regulations that entered into force on July 3, 2016, persons holding managerial positions in Revenio Group Corporation and their closely related parties have had to notify the Company and the Financial Supervisory Authority of any transactions involving Company shares or other financial instruments. The Company publishes information on the transactions in stock exchange releases. In addition to the members of the Board of Directors and President & CEO, the members of the Group Management Team constitute persons holding managerial positions (members of management with an obligation to notify).
The Company maintains project-specific insider registries of persons with access to inside information. The insider registries are not public, but the information in them is provided to the Financial Supervisory Authority.
Members of management with an obligation to notify and other persons specifically defined by management cannot 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. In addition, those participating in projects involving insiders may not, during the project, trade in securities or derivatives issued by the Company.
Group Management is to supervise compliance with the Guidelines for Insiders and maintain the Company's insider registers in cooperation with Euroclear Finland Ltd. The Company's insiders are to be regularly sent an extract of the information entered into the insider register. Their adherence to the restrictions on trading is 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
1. Please fill in the transaction notification form
The form is available at:
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.
The filled form attached to an e-mail is sent to the Company and the Financial Supervisory Authority as follows:
Sending to the Financial Supervisory Authority: Go to securemail.bof.fi and send the form as a secured e-mail to firstname.lastname@example.org
Sending to Revenio Group Corporation: Send the form attached to an e-mail to email@example.com
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.