As of 3 July 2016, the Company complies with EU Regulation on Market Abuse (EU N:o 596/2014) and the so called 2- and 3-tier EU-regulation which supplement it as well as the Insider Guidelines provided by Nasdaq Helsinki Oy as the minimum level regulation in insider matters. In addition, the Company has its own in-house Insider Guidelines of Neste Group which have been approved by the Board of Directors on 9 June 2016 and which set, to some extent, stricter requirements than the above mentioned minimum level regulation.
The Company has defined the members of the Board of Directors and its secretary, the CEO and the members of the Neste Executive Board and its secretary as persons discharging managerial responsibilities in Neste (“managerial persons”). The managerial persons and their closely associated persons shall each notify the Company and the Finnish Financial Supervisory Authority of the transactions conducted on their own account relating to equity or debt financial instruments of the Company or derivative instruments linked thereto. Such notification shall be made without delay and at latest within three (3) business days after the transaction in question was conducted. The notifications to the Company and the Finnish Financial Supervisory Authority can be made most easily in Finnish at www.neste.com/kaupat and in English at www.neste.com/trading by following the instructions provided therein. As of 3 July 2016, the Company shall publish the transactions of the managerial persons and their closely associated persons on a stock exchange release within the same deadline of three (3) business days and, thereafter, such information will also be available on the Company’s website. In addition, the previous public Register on Insiders Subject to Declaration Requirement and their closely associated person has been updated up to 2 July 2016 and is available as of 3 July 2016 on the Company’s website.
Furthermore, the Company has defined certain other persons who act in the informative core of the Company or have access to such informative core on the basis of their tasks for the Company (“core persons”). Typically, such core persons include persons preparing interim reports and financial statement bulletins and persons who are responsible for finance, financial reporting or communication and those having access to such information, as well as certain other executives.
Managerial persons and the core persons shall not trade or conduct other transactions, on their own account or for the account of a third party, directly or indirectly, relating to the Company’s financial instruments during the time between the end of an interim quarter or a financial year and the publication of the corresponding interim report or the year-end report, however, so that the trading is always prohibited for the minimum period of 30 calendar days before the publication of the interim report or the year-end report, respectively (so called closed period).
Furthermore, the Company maintains project or event specific insider registers on all persons who have access to inside information and who work under an employment agreement or otherwise take care of tasks through which they have access to inside information (“project-specific insiders”). Persons who take part of planning and preparation of an insider project or event, for examples mergers and acquisitions, are typically deemed to be insiders of that project or event. A project-specific insider shall not trade or conduct other transactions relating to the Company’s financial instruments until the expiration or publication of that project. The same restriction shall apply to their dependent children as well as to corporations under their direct or indirect control.