Corporate Governance

Insider management

In addition to the regulations applied to First North companies, Vincit Plc complies with the insider guidelines issued by Nasdaq Helsinki Oy. To supplement legislation and other guidelines, the company also has its own insider guidelines confirmed by the Board of Directors.

MAR makes no distinction between permanent and project-specific insiders. Maintaining a separate list of permanent insiders is left to the company’s discretion, and Vincit Plc has opted not to establish a list of permanent insiders. In accordance with the Market Abuse Regulation ((EU) N:o 596/2014, ”MAR”) that entered into force on July 3, 2016, the company has no public insiders.

Project-specific insider lists are drawn up for projects undertaken by the company. The Board of Directors or CEO of Vincit Plc decides on a case-by-case basis whether each set of measures or arrangement constitutes a project. A project refers to a specific set of measures or arrangement being confidentially prepared by the company, which constitutes insider information in the opinion of the company, and whose announcement the company has decided to postpone. Project-specific insider lists are not public. Project-specific insiders are those who participate in the preparation of the project or are otherwise aware of the confidential project.

Closed window

Vincit follows a closed window policy before announcing its results. During the closed window, Vincit's key management personnel, i.e., members of the Board of Directors and the management team, are not allowed to trade in Vincit's financial instruments for a period starting 30 days before the publication of each financial statement, half-yearly report and business review and ending on the day following the publication of such information. At other times, trading in Vincit's financial instruments is permitted provided that the person is not on a project-specific insider list at that time or is not otherwise in possession of inside information.

In addition, the company has set and extended closed window for those taking part in the preparation, drawing up and publication of the company’s financial reports.