Insider management

Harvia complies with the Market Abuse Regulation ((EU) No. 596/2014, “MAR”), including its amendments, and regulations issued under it, instructions issued by the authorities, including the insider guidelines of Nasdaq Helsinki Ltd. In addition, the company has supplemented Nasdaq Helsinki Oy’s insider guidelines with its own insider guidelines.

The company maintains a list of employees and service providers who have access to insider information. The company’s insider list comprises one or more project-based insider lists. The company has estimated that it does not have insiders who would require a separate supplement to the insider list.

The company has appointed a person in charge of insider issues, who is responsible for maintaining insider lists, handling trading restrictions and the management of the obligation to notify and disclose transactions, internal communications related to insider issues, training on insider issues and the supervision of insider issues.

Harvia has internal procedures for publishing insider information, possible delayed disclosure of insider information and the maintaining of project-specific insider lists.

Management transactions

Harvia has determined that managers, whose transactions shall be notified, includes members of the Board of Directors, the CEO, and members of the Management Team. These persons and their closely associated persons are required to notify the company and the Financial Supervisory Authority of every transaction conducted on their own account relating to the shares, debt instruments, derivatives or other financial Instruments of Harvia. Harvia discloses the information via a stock exchange release without delay, at the latest within three business days following the execution of the transaction.

Managers may not conduct any transactions on their own account or for the account of a third party, directly or indirectly, relating to Harvia’s shares, debt instruments, derivatives or other financial instruments during a closed period of thirty (30) calendar days before the publication of an interim financial report, half-year report or year-end report

Trading restrictions

Harvia observes the trading ban on managers (closed window) specified in MAR article 19(11). In addition, the company has separately defined specific individuals who participate in preparing financial reports, or who have access to information related to such reports, as being restricted by a trading ban of similar length and content (closed window).