Insiders
Rovio observes the Market Abuse Regulation (EU 596/2014, "MAR") and the regulations and guidance given under it, including the insider guidelines of Nasdaq Helsinki Ltd. In addition, the company has issued supplementing internal Insider Rules.
Rovio has defined the members of the Board of Directors, the CEO and other members of the Leadership Team as persons discharging managerial responsibilities (“managerial persons”). The managerial persons and their closely associated persons are required to notify Rovio and the FIN-FSA of every transaction conducted on their own account relating to the Financial Instruments of (or linked to) Rovio without delay and at the latest within three business days after transactions in question were conducted. In addition, Rovio discloses via stock exchange releases and its website information on transactions by managerial persons and their closely associated persons.
The managerial persons may not conduct any transactions on their own account or for the account of a third party, directly or indirectly, relating to Rovio’s shares or other financial instruments during a closed period of thirty (30) calendar days before the announcement of an interim financial report, half year report or a year-end report, including the day of publication of said report.
Rovio has further expanded same trading restrictions during the closed period to cover such employees and other persons, who are not managerial persons but may have access to information on the interim financial report(s) or the year-end report or otherwise have regular access to essential financial information of Rovio due to their position or duties at Rovio (so-called “closed period employees”).
Rovio’s insider list comprises one or more project-based insider lists. Rovio can also create a list of “permanent insiders” who, due to the nature of their role or position, continuously have access to all inside information within the company. Rovio maintains a list of employees and service providers who have access to inside information.
Trading in the shares or other financial instruments of Rovio is always prohibited when holding inside information relating to Rovio or its financial instruments, regardless of whether the person has been entered into an insider list.
Rovio’s General Counsel is responsible for insider guidelines and general insider management in the Company.