Marimekko’s Insider Policy
Marimekko Corporation’s Insider Policy is based on the Guidelines for Insiders of Nasdaq Helsinki Ltd., Market Abuse Regulation (“MAR”), which entered into force on 3 July, 2016 and other related regulation and guidance. Marimekko Insider Policy (“Policy”) reflects the main obligations of insiders of Marimekko Corporation (“Marimekko” or the “Company”), as well as describe the trade reporting of managers and their closely associated persons under the Market Abuse Regulation (596/2014, “MAR”) and related regulation and guidance.
The Board of Directors of Marimekko Corporation confirms the Policy.
Insider lists and trading restrictions
Marimekko is obligated to draw up and maintain a list of all persons who have access to inside information and who are working for Marimekko under a contract of employment, or otherwise performing tasks through which they have access to inside information (such as advisers, accountants or credit rating agencies). Marimekko has decided not to maintain a list of permanent insiders. Consequently, all persons having inside information will be included as deal-specific insiders for the relevant projects. Establishment of each such project/event is determined simultaneously with the decision to delay disclosure. Deal-specific insider lists are not public. Marimekko’s Insider Administration is responsible for the maintenance of the insider lists. Persons entered in the deal-specific insider list of Marimekko are not allowed to trade in the Company´s financial instruments during the validity of the project.
Preparation of periodic disclosure (interim reports, financial statement bulletin) or regular access to unpublished financial information is not regarded as an insider project, nor does the Company resolve to delay disclosure in relation thereto. However, due to the sensitive nature of the unpublished information on the Company’s financial results, the Company applies principles stated in the Policy, such as maintaining a list of persons who have authorized access to unpublished financial result information and a closed period before the publishing of annual and/or interim results.
Trading in financial instruments relating to Marimekko is always prohibited when a person holds inside information concerning Marimekko or its financial instruments.
Transactions of managers and their closely associated persons
Managers (Members of the Board of Directors and Management Group) and their closely associated persons are required to notify Marimekko and the Finnish Financial Supervisory Authority (“FIN-FSA”) 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 to him/her and notify to the Company in writing the names and other required information of such persons. The obligations of the Managers according to MAR, such as obligation to notify every transaction, apply also to persons closely associated to Managers and also trading restrictions apply.
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 or members of the Management Group are prohibited to trade in the shares or other financial instruments linked to Marimekko. The closed period applies also to persons participating in the preparation of interim reports and financial statements and to the persons determined by the company having, based on their position or access rights, access to the unpublished financial result information.
Supervision of the Policy
The General Counsel of the Company is responsible for the insider administration. Marimekko’s employees may report actual or potential infringements of this Policy or financial market regulation in accordance with the internal anonymous procedure of Marimekko.