These insider guidelines include the instructions and policies of Endomines Finland Plc and its Group companies in terms of inside information and trading procedures. In insider management, the company complies with Regulation (EU) No 596/2014 (Market Abuse Regulation, as amended, “MAR”) and the lower-level regulations adopted pursuant to the MAR, the Securities Markets Act (746/2012, as amended), the guidelines issued by the authorities and the insider guidelines of Nasdaq Helsinki Ltd. The rules and guidelines of the stock exchange are available at: https://www.nasdaq.com/solutions/rules-regulations-helsinki.
These insider guidelines are binding on all persons employed by the company and its Group companies, as well as the members of the Board of Directors of the company. The insider guidelines also apply to all persons otherwise acting on behalf of the company when they perform tasks that give them access to insider information. Such persons may include, for example, advisors, auditors and credit rating agencies.
If the company decides to postpone the disclosure of insider information, it will establish a non-public insider list. The list will include all persons who have access to project- or event-specific insider information. A person registered in an insider list will be notified in writing of this and the ensuing obligations, as well as the consequences applicable to insider trading and the unlawful disclosure of insider information.
The company’s insider lists are maintained using an electronic system that complies with the requirements of the law.
The maintenance of a project-specific insider list ends once the project has been published or expired. A person registered in a project-specific insider list will be notified of the completion of the project and the closure of the project-specific insider list.
Trading restrictions and prohibition on the use and disclosure of insider information
Once the person has received insider information, they may not trade in the company’s financial instruments during the project. The restriction will apply for as long as the person is involved in the project or until the project has been duly completed.
A member of the management or the Board of Directors may not carry out, on their own account or on behalf of a third party, transactions in the company’s financial instruments during a closed window that begins 30 days before the publication of the company’s financial statements bulletin, business review or half-year report and ends 24 hours after the publication.
The prohibition on the use and disclosure of insider information applies regardless of whether the person has been included in a project-specific insider list or whether they are subject to a trading restriction. The prohibition on the use and disclosure of insider information will remain in force until the information has been made public or until it has otherwise lost its insider nature because of the completion of an insider project, for example.
Transactions involving members of the management and their related parties
Based on the Market Abuse Regulation, the members of Endomines’ management and their related parties must report transactions on their own account in the company’s financial instruments to the company and the Financial Supervisory Authority without delay and no later than three business days from the transaction. The company must announce such transactions by means of company releases without delay and no later than two business days from receipt of the notification.
Transactions subject to the notification obligation
The members of the management and their related parties have an obligation to report all transactions on their own account in the company’s financial instruments when the maximum limit of EUR 5,000 has been reached during a calendar year. This limit is calculated by adding together, without netting, all transactions carried out in the company’s financial instruments during the calendar year.
Reporting of transactions
A member of the management and their related parties must notify the Financial Supervisory Authority of their transactions without delay and no later than three business days from the implementation of the transaction (T+3). Notifications are submitted through the Financial Supervisory Authorities’ online services at https://asiointi.finanssivalvonta.fi/ in accordance with the instructions provided on the FSA website.
Notification to the company
A member of the management and their related parties must also notify the company of their transactions without delay and no later than three business days from the implementation of the transaction (T+3). Notifications are submitted by sending a summary to the company of the form submitted electronically to the Financial Supervisory Authority.
LEI code: 7437004UOFZRIUWTUG97
Share ticker symbol: PAMPALO
ISIN code: FI4000508023
Notification number: Will be generated automatically on the form
On the third page (“Summary”) of the notification, you can see the completed notification in both the XML and stock exchange release format. Copy this information from the page and submit it to the company by e-mail: firstname.lastname@example.org.
The company will disclose transaction notifications by means of a stock exchange release without delay and no later than two business days from receipt of a transaction notification from a member of the management or their related parties. Endomines is not responsible for the accuracy of the information submitted by members of the management of their related parties.
The company’s communication specialist serves as its insider officer, with the CFO as their deputy.
Regardless of these insider guidelines and other instructions provided by the company, each employee of the company is personally responsible for complying with the applicable laws, regulations and guidelines related to insider information.