Insiders and the insider register

Insider information

Insider information is defined in Article 7(1) of the Market Abuse Regulation. Insider information is information of a precise nature which has not been made public, relating, directly or indirectly, to one or more issuers or to one or more financial instruments. If such information were made public, it would be likely to have a significant effect on the prices of those financial instruments or on the price of related derivative financial instruments. The company defines in each case whether the matter at hand is insider information. The company handles insider information carefully and in a way that does not compromise its confidentiality.

Forbidden use of insider information

The use and disclosure of insider information is forbidden. The prohibition of insider trading and illegal disclosure of insider information applies to all natural persons and legal persons in possession of insider information regardless of where and how such information was obtained when such person knows or should know that he or she possess insider information. Chapter 51 of the Finnish Criminal Code stipulates that abuse and aggravated abuse of insider information are both punishable.

Disclosure of insider information and delay of disclosure

The company will disclose insider information concerning the company to the public as soon as possible, unless a decision is taken to delay this upon the fulfillment of the preconditions set out in the Market Abuse Regulation. If the company decides to delay disclosure of insider information, the company shall monitor the fulfillment of delaying criteria throughout the delay process i.e. until the insider information is published or the project in question expires. The company will not disclose information about projects that have lapsed. If the confidentiality of the information that is subject to the delay cannot be guaranteed, the company will publish the insider information as soon as possible.

Project-specific insider registers

If necessary, the company will maintain project-specific insider registers. Project-specific insider registers will be maintained in a situation where the company has decided to delay the disclosure of insider information and established a project-specific insider register concerning insider information.

Persons participating in projects affecting the value creation of the company’s shares belong to the company’s project-specific group of insiders. Persons taking part in the project may not trade company shares, debt instruments or related derivatives or other financial instruments, and any transactions related to them are forbidden until the project either expires or is published.

Persons discharging managerial responsibilities

Persons discharging managerial responsibilities and their related parties shall notify transactions in the shares or debt instruments of the company or derivatives or other financial instruments linked thereto. The obligation to notify transactions applies to all transactions after a total amount of EUR 5,000 has been reached within a calendar year. Solteq has defined Board members and Executive Team members as persons discharging managerial responsibilities pursuant to the Market Abuse Regulation. Persons discharging managerial responsibilities and their related parties are obliged to notify the company and the Finnish Financial Supervisory Authority of any transactions in financial instruments of the company. Persons discharging managerial responsibilities and their related parties are also under the same obligation to fulfill his/her obligation to notify when the management of their securities or making of notifications has been given to another party to perform, such as a portfolio manager. Solteq Plc publishes any notifications it receives with a stock exchange release. In addition, persons discharging managerial responsibilities shall time their trading in the company financial instruments of the company so that it does not erode trust in the securities markets.