Sanoma’s insider administration

Sanoma has an Insider Policy, approved by the Board of Directors’, which complies with the Guidelines for Insiders issued by Nasdaq Helsinki Ltd. Sanoma’s guidelines on insider administration are presented on Corporate Governance Statement.

Corporate Governance

Sanoma has no permanent insiders. Sanoma maintains project and event specific insider lists when necessary according to the Market Abuse Regulations ((EU) N:o 596/2014, ‘MAR’).

Closed period

Sanoma follows the closed period of 30 calendar days before the announcement of year-end Financial Statements Release and Interim Report, provided by the MAR regulation. The members of the Board and the President and CEO shall not conduct any Transactions in Sanoma Instruments on own account or on account of a third party during the Closed Period. Transactions are also not allowed during the entire publication day. In addition Sanoma recommends that EMG members and persons engaged in financial reporting process do not trade in Sanoma Instruments during the Closed Period and on the publication day.

Managers’ transactions

Whenever there are changes in the shareholding of the members of Board of Directors, President & CEO or persons closely associated with them, Sanoma will publish a notification. Published transaction notifications can be viewed here. Their direct holdings at the end of the last financial year are presented in Corporate Governance Statement.

The picture below illustrates the process that the Board members, the President and CEO, and “Persons Closely Associated” with them strictly need to comply with when notifying Transactions in Sanoma Instruments to Financial Supervisory Authority (FSA) and Sanoma.

Guidelines to directors for making the notification can be found here.