Insider administration is organised according to the applicable European Union and local laws and regulations. The Board has also approved groupwide rules to facilitate employees' compliance with the applicable rules and to ensure that inside information is identified as such and treated appropriately.
The Company has identified members of the Board and GLT as well as the Chief Audit Executive as persons discharging managerial responsibilities (as defined in the EU Market Abuse Regulation No 596/2014 (MAR)) who, along with persons closely associated with them, are required to notify the Company and the relevant financial supervisory authority of their transactions in the financial instruments issued by Nordea. The Company publishes such transactions through stock exchange releases.
Persons discharging managerial responsibilities are prohibited from trading in the financial instruments of Nordea whenever such persons possess inside information regarding Nordea, as well as during a period of 30 calendar days before (and including) the date of the publication of an interim financial report, half-year report or a year-end report by Nordea.
Nordea does not maintain a permanent insider register under MAR. Insiders are identified on a case-by-case basis for specific projects and are notified of their insider status. Persons included in a project-specific insider register are prohibited from dealing in Nordea’s financial instruments as long as they are included on such a list.
For employees who participate in providing investment services or advice, the Company also applies groupwide trading restrictions that are based on the trading rules established by for example, Finance Finland, the Swedish Securities Dealers Association and the Swedish Investment Fund Association. Furthermore, in their capacity of a company licensed to provide investment services and as a fund management company, the Company and its subsidiary Nordea Funds Ltd, respectively, maintain insider registers of persons who are classified as “insiders” pursuant to the Finnish Act on Investment Services and the Finnish Act on Mutual Funds. The holdings of such persons in securities listed in Finland are public information and are updated automatically in the public insider register kept by Euroclear Finland Oy. The register of holders of units in funds managed by Nordea Funds Ltd is also available for viewing at Nordea Funds Ltd.
The responsibilities of Nordea’s insider administration include internal communications related to insider matters and trading restrictions, setting up and maintaining its insider registers, arranging related training as well as organising and overseeing compliance with the insider rules. Group Compliance bears overall responsibility for monitoring compliance with the groupwide rules on prohibition of insider trading, trading restrictions for persons discharging managerial responsibilities and personal account dealing.
Updated February 2020