Insider administration

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The insider administration is organised according to the applicable European Union and local laws and regulations. The Board has also approved Group-wide rules to facilitate for employees to comply with the applicable rules and to ensure that inside information is identified as such and treated in an appropriate manner. 

Nordea has identified members of the Board and Group Executive Management (GEM) as well as the Chief Executive Audit as persons discharging managerial responsibilities (as defined in the EU's Market Abuse Regulation (MAR)) who, along with persons closely associated with them, are required to notify Nordea and the relevant Financial Supervisory Authority of their transactions in the financial instruments issued by Nordea. Nordea publishes such transactions as stock exchange releases.

Persons discharging managerial responsibilities are only permitted to trade in financial instruments issued by Nordea during the two-week period following the publication of an interim financial report or year-end reports. In exceptional circumstances and based on written request from a person discharging managerial responsibilities, the Head of Group Compliance may grant permission for such person to trade on his or her own account or for the account of third party outside of the two-week open window period.

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 list. 

For employees who participate in providing investment services or advice, Nordea also applies Group-wide trading restrictions that are base on the trading rules establised by for example Finance Finland, the Swedish Securities Dealers Association and the Swedish Investment Fund Association. Futhermore, in their capacity as 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 "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 is 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 held available at Nordea Funds Ltd.

Nordea's insider administration responsibilities include internal communications related to insider matters and trading restrictions, setting up and maintaining its insider registers, arranging related trainings as well as organising and overseeing compliance with the insider rules. Group Compliance is overall responsible for monitoring the compliance with the Group-wide rules on, inter alia, prohibition of insider trading, trading restrictions for persons discharging managerial responsibilities and personal account dealing. 

Updated: February 2019