Insider Administration

Following the market abuse regulation (MAR) listed companies (issuers) such as Aktia Bank plc (Aktia) has the obligation to set up insider lists and a list of persons discharging managerial responsibilities and persons closely associated with the company. The obligation to set up insider lists also concerns persons acting on the company's behalf or on the company's account.

To be included in the list of persons discharging managerial responsibilities and persons closely associated with them are persons discharging such responsibilities in the company as specifically enumerated in the market abuse regulation and persons closely associated with them. To be included in the insider lists are all persons who have access to inside information and who are working for them under a contract of employment, or otherwise performing tasks through which they have access to inside information, such as advisers, accountants or credit rating agencies.

In accordance with the market abuse regulation trading restrictions (a closed period), starting 30 calendar days before the announcement of an interim financial report or a year-end report is published and ending the banking day following the publication, are applicable to persons discharging managerial responsibilities. According to the market abuse regulation, notification and disclosure obligations also apply to persons discharging managerial responsibilities for transactions conducted relating to the company's financial instruments. Information on notification and disclosure applying to persons discharging managerial responsibilities regarding transactions relating to Aktias financial instruments are found under the topic  Transaction Notification.

In accordance with the insider rules of Nasdaq Helsinki Ltd (Helsinki Stock Exchange), Aktia has stipulated corresponding regulations for persons participating in the production of financial reports who the company regards holding significant confidential information about the contents of the reports.

In addition to the insider regulations applied to Aktia as issuer, the company follows insider rules corresponding the model rules of the Federation of Finnish Financial Services for providers of investments services. Following these rules, information is registered about persons having access to insider information in accordance with the Financial Services and Markets Act and the rules and regulations of the Financial Supervisory Authority. Further, the right of so-called relevant persons to conduct transactions with financial instruments on their own account is restricted so that buying and selling (or selling and buying) the same financial instruments is not allowed, unless the time between the transactions exceeds one month.