Insider administration

Insider administration is organised according to the applicable EU and national level laws and regulations. The Board has approved Group-wide rules and guidelines to provide clear instructions for employees to facilitate their compliance with the rules applicable to ensure that inside information is identified and handled appropriately.

Insiders are identified on a case-by-case basis whenever inside information is detected and are subsequently registered in a related insider register and notified of their insider status. All identified insiders are then prohibited from 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. Nordea does not maintain a permanent insider register under EU Market Abuse Regulation No 596/2014 (MAR).

The Company has also identified members of the Board and the GLT as well as the CAE as persons discharging managerial responsibilities (as defined by MAR) who, along with persons closely associated with them, are required to notify the Company and the relevant financial supervisory authority of any transaction in financial instruments, issued by Nordea, executed on their account or on their behalf. The Company 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 financial report, half-year report or year-end report and whenever such persons are in possession of inside information about Nordea.
For employees who participate in providing investment services or advice to customers, the Company also applies 
Group-wide internal trading restrictions and transaction reporting obligations that are based on the trading rules established by, inter alia, 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, the Company 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 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 training of and providing information to employees who are exposed to inside information, to make sure that they are aware of the restrictions and obligations placed on insiders, setting up and maintaining insider registers as well as monitoring compliance with the insider rules. The rules are put in place to mitigate the risk of insider dealing and other forms of market abuse, and the overall responsibility for making sure that a high level of knowledge of and compliance with these rules is maintained lies with Group Compliance.