Mandatum plc’s Board of Directors has approved Mandatum Group’s (“Mandatum”) Insider Policy which takes into account the Group’s business area and extensive investment activities as well as listed company obligations. The policy is binding on all Mandatum Group employees and the members of the Board of Directors. The Insider Policy takes into account current supranational regulation, such as the Market Abuse Regulation (Regulation (EU) No 596/2014 (MAR) of the European Parliament and of the Council), as well as applicable national regulation, including Nasdaq Helsinki’s Guidelines for Insiders and the Financial Supervisory Authority’s regulations, statements and interpretations.
In accordance with the MAR and Nasdaq Helsinki’s guidelines, Mandatum applies a so-called closed window trading restriction to the Group's Management Team and to the persons working with interim reports and other financial reports, according to which the persons subject to the restriction are not allowed to acquire or sell Mandatum's financial instruments for 30 days prior to the release of Mandatum's financial report. In addition, Mandatum has decided to apply a short-term trading restriction to these persons. Short-term trading restriction means that the time between the acquisition and sales or sales and acquisition of the same financial instrument must be at least 30 days.
In addition, Mandatum Group's personnel participating in the provision of investment services are subject to trading restrictions (short-term trading restriction and closed window). A public insider list is maintained of persons participating in investment services.
In addition to regulatory supervision, compliance with the obligations arising from the Insider Policy and the underlying legislation is supervised in Mandatum Group by the Insider Administration, a group function centralised in Mandatum plc and led by the person in charge of insider matters.
Notifications (Managers' Transactions) as laid down in Article 19 of the Market Abuse Regulation can be found in Releases.
As a rule, Mandatum Group companies may not enter into agreements or transactions with their related parties on terms that differ from those normally applied by the Group company in question, or which are otherwise commercially unjustified or favourable to certain parties. All related party transactions must be agreed in writing and in the ordinary course of business. Mandatum Group’s related party transactions are typically related to purchases of internal services or related to other services or products that are part of the ordinary business of the Group company. Related party transactions that are not part of the company's ordinary course of business or are carried out in deviation from customary commercial terms, require a decision by the Board of Directors before they are carried out.
Mandatum Group maintains a register of Mandatum Group’s related parties and reported related party transactions. Related party transactions are reported annually to the Audit Committee of the Board of Directors, and the Audit Committee monitors and evaluates how Mandatum and its related parties’ agreements, and other legal actions meet the requirements of belonging to Mandatum’s ordinary course of business and arm’s length principle.
Mandatum assesses and monitors the transactions carried out with its related parties to ensure that any conflicts of interest are addressed appropriately in decision-making. Mandatum plc’s Board of Directors has adopted Mandatum Group’s internal policy concerning related party transactions, whose purpose is to ensure that Mandatum has effective mechanisms in place to identify, manage, monitor and report related party transactions.