Medicortex has prepared its own insider rules which include the procedures and instructions for the Company’s personnel and management. The guidelines have been approved by the Board of Directors on 3 June 2022. The Company’s Insider Guidelines supplement the provisions on insider trading set forth in the Finnish law, and regulations and instructions included, for example, in the Market Abuse Regulation (EU 596/2014, “MAR”, including amendments), Nasdaq Helsinki Ltd’s Guidelines for Insiders (as amended), and the rules and regulations of the Finnish Financial Supervisory Authority.
The Company will disclose inside information directly concerning the Company as soon as possible.
Definition of inside information
Inside information means information of a precise nature relating directly or indirectly to one or more issuers or one or more financial instruments which has not been made public and which, if made public, would be likely to have a significant effect on the prices of the said financial instruments or on the prices of derivative financial instruments related thereto.
Restrictions on trading and closed window
The Managers and their closely associated persons are obliged to notify the Company and the Finnish Financial Supervisory Authority of transactions in the Company's financial instruments promptly and no later than three (3) days after the transaction.
The Managers shall not execute any transactions on their own account or for the account of a third party in the Company's financial instruments prior to the announcement of the Company's half-year report or financial statements bulletin during a period commencing 30 days before the announcement of the half- year report or the financial statements bulletin and ending at the end of the day subsequent to the publication day of such report (the ”Closed Window”). Should the financial statements contain material information that has not been published previously in the financial statements bulletin, such as future prospects, the Closed Window applies also to the financial statements.
Supervision of insider issues
Compliance with the obligations set out in the Insider Guidelines shall be supervised by the CEO in accordance with the instructions issued by the Finnish Financial Supervisory Authority and other authorities.
The Company will immediately notify the Finnish Financial Supervisory Authority, which acts as the supervisory authority in insider issues, of any possible abuse of inside information or other actions breaching insider regulation that are brought to the Company's attention on the basis of its supervision or otherwise. In addition, the Company may notify the Finnish Financial Supervisory Authority of any actions that are contrary to a regulatory order or guidance or the Insider Guidelines.
The Company has set up a whistleblowing procedure through which Company's employees may report if there is reasonable doubt that a person employed by the Company would have breached regulations and provisions concerning securities markets.