Insider management

In insider matters, Bilot complies with Finnish law, Regulation (EU) No 596/2014 of the European Parliament and of the Council (“MAR”) on market abuse, rules and regulations that supplement the above and Nasdaq Helsinki Guidelines for Insiders. In addition, the company has its own insider guidelines established by its board of directors.

The company’s CFO Mikko Marttinen is responsible for insider administration.

Bilot publishes any insider information with direct relevance to the company as quickly as possible. Should certain conditions set in MAR be met, Bilot may delay publication of insider information. Should Bilot decide to delay the publication of insider information, the company shall draft a project-specific non-public insider list which shall be kept up to date.

Closed window

The members of the Board of Directors and the Management Team shall not trade with Bilot’s financial instruments for a period commencing 30 days before the publication of each financial statement bulletin and mid-year review and ending on the day following the publication of such information.

The company has also established an expanded closed window for persons involved in the preparation, drawing up and publishing of the company’s financial reports.

Managers’ transactions

Members of Bilot’s Board of Directors and Management Team as well as persons closely associated to them shall inform Bilot of any business transactions they have made on their own behalf using Bilot’s financial instruments without delay and within one working day of said transaction, at the latest,  and shall inform the Financial Supervisory Authority of said transaction within three working days, at the latest. Bilot shall publish said business transactions as company releases without delay and within three working days of said transactions.