Insider policy

DNA complies with the rules and instructions of Nasdaq Helsinki Oy, such as its insider guidelines, the Market Abuse Regulation ((EU) No. 596/2014, MAR), the Level 2 Regulations issued under it, the provisions of the Securities Market Act and the Penal Code, and the rules and guidelines of the Financial Supervisory Authority and ESMA (the European Securities and Markets Authority). These are supplemented by the company’s own guidelines for insiders, the aim of which is to provide clear operational guidelines and rules on the management of insider issues, disclosure of inside information, maintenance of lists of insiders and the transactions of the company’s management and their closely associated persons.

DNA discloses all inside information directly related to the company as soon as possible. DNA may delay the disclosure of inside information if all conditions under applicable regulations for delaying the disclosure of inside information are met. The company publishes all disclosed inside information on its website and keeps it there for at least five years. DNA maintains project-specific insider registers in situations required under applicable regulations.

Each person who serves in a management position at DNA must notify the company of all persons closely associated to them, and of any changes in this information. DNA will draw up a list of members of the management and their closely associated persons. DNA’s management and their closely associated persons notify both DNA and the Financial Supervisory Authority of all transactions conducted on their own account relating to DNA’s financial instruments. DNA, in turn, publishes these transactions through a stock exchange release. Notifications and disclosures are carried out within the time limits set by legislation.

A member of the management is not entitled to conduct transactions on their own account or on the account of a third party with DNA’s financial instruments during a 30-day closed period preceding the publication and including the date of publication of the company’s financial statements release or interim report (trade restriction).

The person responsible for the company’s insider issues is the Senior Vice President of Legal Affairs. She is responsible, for example, for the implementation of the following tasks at the company:

  • internal communications about insider issues;
  • training related to insider issues;
  • drawing up and maintaining lists of insiders, and providing them to the Financial Supervisory Authority (on request);
  • obtaining approvals from the persons included in the lists of insiders;
  • monitoring of insider issues; and
  • monitoring of regulatory changes related to insider issues.