Insider Management

Insider management

Steady Energy abides by applicable Finnish and EU legislation, including the EU Market Abuse Regulation ((EU) 596/2014, as amended), the Finnish Limited Liability Companies Act, the Finnish Securities Markets Act, the Finnish Penal Code, Nasdaq Helsinki’s guidelines for insiders of listed companies, the rules and regulations of the Nasdaq First North Growth Market Finland marketplace, and the regulations and guidelines issued by the European Securities and Markets Authority and the Finnish Financial Supervisory Authority.

In addition, Steady Energy’s insider policy, approved by the Board of Directors, complements the applicable insider regulations and defines the procedures concerning the company’s insider management and individuals involved in insider projects.

Administration of inside matters

The person responsible for Steady Energy’s insider matters, or the Insider Manager, is the CEO.

The CFO will act as a deputy for the Insider Manager.

The Insider Manager is responsible for the internal communications and training related to insider issues as well as for monitoring compliance with the insider rules. The Insider Manager is also responsible for preparing and maintaining the company’s insider lists as well as for distributing information on matters pertaining to trading restrictions and publishing managers’ transaction notifications.

The company has internal procedures in place for employees to report suspected fraud or other violations, including any breaches of financial markets regulation in the company. The employees may submit their reports through Steady Energy’s Whistleblowing channel found on the company’s website.

Trading restrictions

The company’s managers (including persons controlled by them) are prohibited from trading or directly or indirectly executing transactions relating to the company’s financial instruments for their own account or for the account of a third party during a period that begins 30 calendar days before the announcement of a half-year report or a year-end report and ends on the day following their publication (closed window). The company does not repurchase its own shares during this period. The company may grant an exemption from this trading ban only in the situations permitted by Article 19 (12) of the MAR. The decision on the exemption is made by the Company's CEO.