Insider issues

Boreo's insider management

Boreo has compiled Insider Guidelines that complement the Market Abuse Regulation (596/2014, "MAR"), the Securities Market Act (746/2012), and the Criminal Code of Finland (39/1889), as well as the rules and regulations of the Financial Supervision Authority, the European Securities and Markets Authority (ESMA), and Nasdaq Helsinki Oy.

The Insider Guidelines are intended to create clear procedures and rules for the management of insider issues, the publication of inside information, the maintenance of insider lists and management transactions, and to prevent the abuse of inside information.

The Insider Guidelines have been approved by the Board of Directors and are applicable to the Company’s insiders including the members of the Company's board and members of Boreo's management group. In addition, the guidelines contain regulations that apply to all company employees that have access to inside information and to the immediate circle of the insiders. Each person is personally responsible for following the guidelines; the Insider Guidelines are available on the Company’s website and have been provided to all persons included in the insiders. Each person is also independently responsible for evaluating whether the information they possess is inside information.

The Company's insider issues and maintaining the insider list are the responsibility of Boreo’s CEO.

Persons on the insider list are not allowed to trade in the company’s financial instruments on their own or a third party’s account during a closed period of 30 days before the publication of a financial statement release or an interim or half-year financial report or on the date of such publication.

Each person is always responsible for ensuring that any trading in the Company’s financial instruments, recommending trading to another person or the disclosure of inside information is permitted under the laws, regulations and guidelines in force at the time. Managers and the persons closely associated with them must notify transactions in the Company’s financial instruments to the Company and the Financial Supervision Authority, which the Company publishes in a stock exchange release and on the Company’s website.