Disclosure policy

In all its communications, the company shall comply with the guidelines, rules and regulations of Helsinki Stock Exchange, First North, ESMA (European Securities and Markets Authority) and the Financial Supervision Authority as well as Regulation (EU) No 596/2014 (“MAR”) on market abuse and with the duties of companies listed in First North set in the Finnish Securities Markets Act, the Limited Liability Companies Act and other legislation.

The purpose of the disclosure policy is to establish the central principles and practices by which Bilot conducts communications with capital markets, the media and other interest groups. The Board of Directors approved the disclosure policy on 31 January 2020 and it will be updated as necessary. This is an abstract of the disclosure policy approved by the Board of Directors.

Objectives and key disclosure principles

The objective of Bilot’s investor communication is to support the appropriate creation of shareholder value. The goal is to ensure that all market participants have information that is sufficiently trustworthy, comprehensive, timely and comparable to help them make their investment decisions. The central principles of communication are impartiality, concurrency, coherence, relevance and sufficiency.

Responsibilities of communications and investor relations

The company’s Board of Directors is responsible for publishing financial statement bulletins, financial statements, Board of Directors’ reports, mid-year reviews and possible profit warnings. In addition, the Board of Directors is responsible for the disclosure of information required by First North rules. The CEO, CFO and Director of Markets & Ecosystem are responsible for publishing company releases required as part of the company’s duty of disclosure.

Alexander Corporate Finance Oy acts as the company’s certified advisor in accordance with the rules of First North.

Information channels

Bilot’s primary and most up-to-date information channel is the company’s website at www.bilot.group. All company releases are published in Finnish via Cision Finland Oy, key media and the company’s website at www.bilot.group.

Reporting and publishing languages

The company’s official communication language is Finnish.

Releases

The company publishes directly relevant insider information in company releases, providing that no MAR preconditions for delaying publication are met. Additionally, the company publishes financial statements, mid-year reviews and other information required by current First North regulations.

Company releases are available on the c company’s  website for at least five years after publication and financial reports for at least ten years.

Issues that do not meet the criteria for publication as a company release but which are considered to be of interest to investors and other stakeholders will be published as press releases.

Financial reporting

Bilot publishes financial statement bulletins, financial statements, Board of Directors’ reports and mid-year reviews in accordance with a yearly schedule published in advance. On its website, before the beginning of each financial period, the company publishes an events calendar containing the publication dates of the company’s financial reports, the publication week of the company’s annual report and the date of the Annual General Meeting.

Managers’ transactions

In accordance with MAR, Bilot publishes the business transactions of the company’s manager and persons closely associated with them  using the company’s financial instruments in company releases without delay and no more than three days after said transactions.

The silent period and closed windows

The company adheres to a silent period of 30 days before the publication of financial reports. During this period, company representatives do not meet with representatives of capital markets or the financial media or comment on the company’s financial situation, markets or future prospects.

During a closed-window period, Bilot’s managers shall not trade or conduct any other transactions on their own behalf or on the behalf of a third party with Bilot’s financial instruments.