The objective and key principles followed in Nordea’s investor communications and the publication of financial reports are described in Nordea’s Disclosure Policy. The Disclosure Policy also describes the disclosure, dissemination and storage of the information within the scope of the disclosure obligation as prescribed by rules and regulations. The Disclosure Policy has been approved by the Board and is available at nordea.com.
Insider administration is organised in accordance with the EU Market Abuse Regulation No 596/2014 (MAR) and supplementing legislation as well as applicable national level laws and guidance from financial supervisory authorities. Nordea has Group-wide rules and guidelines in place to provide clear instructions for employees to facilitate their compliance with these rules and to ensure that inside information is identified and handled appropriately at all times.
Insiders are identified on a case-by-case basis whenever inside information is detected and are subsequently registered in a related insider register. All persons identified and registered as insiders are notified of their insider status and the restrictions and obligations that apply to them, including the prohibition against dealing in the financial instrument(s) to which the inside information relates until that information is made public or otherwise no longer deemed to be inside information and the insider register is closed.
The responsibilities of Nordea’s insider administration also include (i) training and providing information to employees who are exposed to inside information to make sure that they are aware of the restrictions and obligations that apply to them as insiders, (ii) setting up and maintaining insider registers and (iii) monitoring compliance with the insider rules.
The rules are in place to mitigate the risk of insider dealing and other forms of market abuse. The overall responsibility for making sure that a high level of knowledge of and compliance with these rules is maintained lies with Group Compliance.
Nordea has identified the members of the Board and the GLT as well as the Chief Audit Executive as persons discharging managerial responsibilities (as defined by MAR). Along with persons closely associated with them, they are required to notify Nordea and the relevant financial supervisory authority of any transaction in financial instruments issued by Nordea, executed on their account or on their behalf. Nordea discloses such reported transactions to the market through stock exchange releases. In addition to this reporting duty, persons discharging managerial responsibilities are prohibited from trading in financial instruments issued by Nordea during a period of 30 calendar days prior to (and including) the date of the publication of a Nordea Group interim report, half-year report or year-end report and whenever such persons are in possession of inside information regarding Nordea.
For employees who participate in providing investment services or advice to customers, Nordea also applies Group-wide internal trading restrictions and transaction reporting obligations that are based on the trading rules established by, among others, Finance Finland, the Swedish Securities Markets Association and the Swedish Investment Fund Association. Furthermore, in the capacity of a company licensed to provide investment services and as a fund management company, Nordea and its subsidiary Nordea Funds Ltd, respectively, maintain insider registers of persons who are classified as “public insiders” pursuant to the Finnish Act on Investment Services and the Finnish Act on Mutual Funds. The holdings of securities listed in Finland of such persons are public information and uploaded to the public insider register kept by Euroclear Finland Ltd. The register of holders of units in funds managed by Nordea Funds Ltd is also available for viewing at Nordea Funds Ltd.