Consti complies with EU Regulation on Market Abuse ((EU) 596/2014, “MAR”) and 2- and 3-tier regulation supplementing it, the Finnish Securities Markets Act, the insider guidelines of Nasdaq Helsinki Ltd as well as guidance issued by authorities. In addition, the company has internal Insider Guidelines which Consti’s Board of Directors has approved and which set, to some extent, stricter requirements than the above-mentioned minimum level regulation.
Insider registers
Consti has defined the members of the Board of Directors, the CEO and members of the Group Management Team as persons discharging managerial responsibilities (“persons discharging managerial responsibilities”). Consti publishes the transactions persons discharging managerial responsibilities and their closely associated persons have conducted relating to financial instruments of Consti in accordance with the notifications the company has received and at latest within two business days after the receipt of the notification. After the publication, information will also be available on the company’s website.
Consti has additionally defined e.g. management team members of Consti's subsidiaries as well as persons dealing with preparation of financial reporting as persons who act in the informative core of the company, i.e. persons who have access to such informative core of the company on the basis of the tasks they deal with (“persons who act in the informative core”). People employed by Consti and people who work for Consti under a contract, and who, due to their duties, have access to insider information associated with Consti, are entered in the company’s project-specific insider register, which is established when necessary.
Trading rules
Persons discharging managerial responsibilities or persons who act in the informative core of the company shall not trade or conduct other transactions, on their own account or for the account of a third party, directly or indirectly, relating to Consti’s financial instruments during the so called closed window. The closed window begins 30 days prior to the publication of Consti’s interim reports or financial statement bulletins. The trading prohibition also applies to the day when results are published. Project-specific insiders are prohibited from trading in the company’s financial instruments until the project concerned has been cancelled or disclosed.
Consti’s CFO is responsible for adherence to insider regulations and for monitoring the duty to declare as well as the maintenance of insider registers.