Marimekko’s insider policy
Marimekko Corporation’s insider policy, based on the Guidelines for Insiders of Nasdaq Helsinki Ltd. and the Market Abuse Regulation (MAR), describes the main obligations of insiders of Marimekko Corporation as well as the trade reporting of managers and their closely associated persons, and other related regulations and guidance under MAR.
The company’s Board of Directors confirms the policy.
Insider lists and trading restrictions
Marimekko maintains a list of all persons who have access to inside information and who work for Marimekko under a contract of employment, or otherwise perform tasks through which they have access to inside information. Marimekko has decided not to maintain a list of permanent insiders. Consequently, all persons having inside information are entered in a project-specific insider list established and maintained for all projects that involve inside information. The decision to establish a project-specific insider list is taken simultaneously with the decision to delay disclosure of inside information. Project-specific insider lists are not public. Marimekko’s insider administration is responsible for the maintaining the insider lists. Persons entered at project-specific insider list of Marimekko are not allowed to trade in the company’s financial instruments during the term of the project.
Preparation of periodic disclosure (interim reports, financial statements bulletin) or regular access to unpublished financial information is not regarded as an insider project, nor does the company resolve to delay disclosure of information in relation thereto. However, due to the sensitive nature of the unpublished information on the company’s financial results, the company applies the principles stated in its insider policy, such as maintaining a list of persons who have authorised access to unpublished financial information and a closed period before the publishing of annual and interim results.
Trading in Marimekko’s financial instruments is always prohibited when a person holds inside information concerning Marimekko or its financial instruments.
Transactions by managers and their closely associated persons
The members of Marimekko’s Board of Directors and Management Group and their closely associated persons are required to notify Marimekko and the Finnish Financial Supervisory Authority of every transaction conducted on their own account relating to the financial instruments of Marimekko. Promptly upon receipt of the notification, Marimekko is required to disclose such information as a stock exchange release.
Each manager shall identify the persons closely associated with them and notify the company in writing of the names of such persons and other required information. According to MAR, the obligations of managers also apply to persons closely associated with the managers.
Marimekko applies a closed period of 30 days before the publishing of annual and interim results. During the closed period, the members of the company’s Board of Directors and Management Group are prohibited from trading Marimekko shares or other financial instruments linked to Marimekko. The closed period also applies to persons participating in the preparation of interim reports and financial statements and to persons determined by the company to have, based on their position or access rights, regular access to unpublished financial information.
Supervision of insider policy
The General Counsel of the company is responsible for insider administration. Marimekko’s employees may report actual or potential infringements of the insider policy or financial market regulation in accordance with the internal, anonymous procedure of Marimekko.