FIT Biotech follows the insider rules set forth in applicable legislation and the standards, directives and guidelines of the Finnish Financial Supervisory Authority, and in addition the insider guidelines of NASDAQ Helsinki and FIT Biotech’s own Insider guidelines approved by the Board of Directors.
Notification requirement of persons discharging managerial responsibilities
FIT Biotech’s persons discharging managerial responsibilities and persons closely associated with them shall notify FIT Biotech and the FIN-FSA about transactions conducted with FIT Biotech’s financial instruments. Hence also persons closely associated with the persons discharging managerial responsibilities have an independent obligation to notify transactions to FIT Biotech and the FIN-FSA.
The persons deemed to discharge managerial responsibilities at FIT Biotech (“Managers”) are:
- Members of the Board of Directors; and
- Members of the Management Team.
FIT Biotech’s insider register is included in the Sire system of the Finnish Central Securities Depository at Euroclear Finland Oy and is maintained by FIT Biotech’s administrative assistant.
The project-specific insider list
The project-specific insider list is created when the company is having a project. All the persons employed or otherwise contractually retained by FIT Biotech that receive inside information related to a single project (project-specific insiders) shall be recorded to a project-specific insider list.
Project-specific insiders include, in addition to the FIT Biotech employees receiving inside information related to a specific project, FIT Biotech’s advisors, financiers and major shareholders to whom FIT Biotech provides inside information concerning the project.
MAR prescribes a closed period of 30 days before the announcement of an interim financial report or a year-end report for persons discharging managerial responsibilities within an issuer.
The company has set up an extended closed window for the persons involved in preparing, arranging and publishing the company's financial reports. FIT Biotech may on case by case basis, if necessary, extend the restriction on trading also to other persons involved in the preparation, drafting and disclosure of the Company’s financial reports.
Above-mentioned persons are not allowed to trade in financial instruments for a period commencing 30 days prior to the publication of each financial statement bulletin and half-yearly report and ends on the day following the publication of this information. At other times, trading on FIT Biotech's financial instruments is permitted provided that at that time a person is not entered on a project-specific list of insiders or otherwise has no insider information.