Insider management

VMP adheres to the Market Abuse Regulation (596/2014/EU, “MAR”), Level 2 Commission Regulations and the rules and guidelines issued by the European Securities and Markets Authority (ESMA), the Finnish Securities Market Act (746/2012, including amendments), the Finnish Criminal Code (89/1889, including amendments) the Nasdaq First North Nordic Rulebook and the Guidelines for Insiders of Nasdaq Helsinki Ltd. In addition, the Company has completed the guidelines with an internal insider policy.

The Company maintains a list of employees and service providers with access to inside information. The insider list includes one or several event-specific insider lists. The Company’s CFO manages the insider list.

Persons discharging managerial responsibilities at VMP and persons closely associated with them are obliged to notify the Company and the Finnish Financial Supervisory Authority of transactions conducted in VMP’s shares, securities under current liabilities or their derivatives or other securities.

Persons discharging managerial responsibilities falling under the disclosure obligation, according to MAR, include members of the governance, management and supervisory bodies of the issue as well as other executive-level managers who are not members of afore-mentioned bodies but with regular access to insider information regarding the issue and have the authority to make decisions falling under the management’s jurisdiction and affect the development and outlook of the issue. The Company’s managerial persons under the disclosure obligation include members of the Board of Directors, CEO and other management team members.

Trading with the Company’s shares or other securities is always prohibited when the person holds insider information on the Company’s or its securities, regardless of whether the person is included in the insider list. Insider persons cannot execute transactions on the Company’s shares or other securities or provide insider information to external parties.

Persons discharging managerial responsibilities may not execute transactions using the Company’s securities on their own account or for a third party during the closed window of 30 days prior to the publication of the financial statement report or interim report, including the date of publication.

VMP’s Chief Legal Officer is in charge of insider matters and their arrangement in the Company.