Insider management

Insider management

VMP adheres to the Market Abuse Regulation (596/2014/EU, “MAR”), Level 2 Commission Regulations and the MAR-related standards issued by the European Securities and Markets Authority (ESMA), the Finnish Securities Market Act, 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 supplemented 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 project-specific insider lists. The Company’s lawyer 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 financial instruments.

Persons discharging managerial responsibilities falling under the disclosure obligation according to MAR include members of the governance, management and control bodies of the issuer as well as other senior managers who are not members of aforementioned bodies but who possess regular access to insider information regarding the issuer and have the authority to make decisions falling under the management’s jurisdiction that affect the development and business outlook of the issuer. The Company’s managerial persons under the disclosure obligation include members of the Board of Directors, the CEO and other Management Team members.

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

Persons discharging managerial responsibilities are also prohibited from executing transactions using the Company’s shares or other financial instruments on their own account or through a third party during the closed period of 30 days prior to the publication of an interim report or financial statements, including the date of publication.

VMP uses an internet-based notification channel, through which it is possible to make an anonymous report of a suspected violation of financial market regulations and decrees.

VMP’s Legal Counsel is responsible for insider matters and for the overall organization of insider management in the Company.