Insider issues

Insider issues

Toivo Group has Insider Guidelines approved by the Board of Directors, which includes policies and guidelines for the company's personnel and management related to Toivo Group’s insider management. The Insider Guidelines complement, e.g.:

  • The market abuse Regulation (EU) No 596/2014 with amendments),
  • The market abuse Directive (2014/57/EU with amendments),
  • Commission Delegated Regulation ((EU) 2016/522 with amendments),
  • Commission Implementing Regulation ((EU) 2016/347 and (EU) 2016/523 with amendments),
  • Domestic regulation, especially Chapter 51 of the Criminal Code of Finland (39/1889 with amendments) and the Securities Markets Act (746/2012 with amendments),
  • The rules and guidelines of Nasdaq Helsinki Oy ("Helsinki Stock Exchange"), such as the insider guidelines that Toivo is obliged to comply with as a listed company on the First North Growth Market Finland marketplace (First North) maintained by the Helsinki Stock Exchange, and
  • The valid rules and regulations concerning insider matters issued by FIN-FSA.

Finance director and chief risk officer Lauri Rekola is the company's insider manager. The insider manager is responsible for insider administration tasks, for project-specific insider lists and the list of managers and their immediate circle and tasks related to informing of trading restrictions and reporting of transactions.

Insider information add

Insider information refers to any information directly or indirectly relating to one or more issuers or to one or more financial instruments, that is precise by nature, has not been published and is likely to have a significant effect on the price of the financial instruments in question or the price of related financial derivatives if it is published. Toivo publishes any direct insider information it has concerning the company as soon as possible. The company publishes the information as a company release and stores all publicly disclosed insider information on its website for at least five years. When certain conditions prescribed in MAR are met, Toivo may postpone disclosure of insider information. The company monitors that the conditions for the delay are fulfilled throughout the delay procedure, i.e., until the insider information has been disclosed or the insider project has lapsed. If one or more of the delay conditions are no longer met, the company will disclose the insider information as soon as possible.

Closed period add

Managers shall not carry out, on their own account or on behalf of a third party, any transaction relating to the financial instruments of the company prior to the publication of the company's business reviews, half-year reports and financial statements bulletins for a period starting 30 calendar days before the publication and ending at the time of publication. If the financial statements contain material information previously undisclosed in the financial statements bulletin, such as future developments, the closed period also applies to the financial statements.

Trading restriction add

Persons (both employed by the company and external advisors) involved in the preparation and compilation of the company's business reviews, half-year reports and financial statements bulletins shall not trade in the company's financial instruments during a period starting 30 days before the publication of the company's business review, half-year report and financial statements bulletin and ending at the time of publication. The company's trading restriction also applies to other persons defined by the company. In addition, the company's trading restriction applies to legally incompetent persons under the supervision of those covered by the restriction and to corporations controlled by the above-mentioned persons. The company has also set up an extended closed period for persons involved in the preparation, compilation and publication of the company's financial reports.

Management transactions add

The management and their immediate circle are obliged to notify without delay and at the latest within three working days of a transaction being completed the Company and the Financial Supervisory Authority of transactions they have carried out with the company's financial instruments. All transactions exceeding the annual threshold of EUR 5,000 shall be reported to the company and the Financial Supervisory Authority.

Notifications are made using the electronic form of the Financial Supervisory Authority and sent to the company by e-mail to and the Financial Supervisory Authority by secure e-mail at to

Reporting of violations (whistleblowing) add

Toivo Group Plc has prepared instructions for handling reports of insider trading and market manipulation, attempted insider trading and market manipulation, as well as illegal or dishonest proceedings related to accounting, internal control, auditing or other company operations by company employees and other entities (“Whistleblowing notification”).

The Board of Directors has appointed the Chairman of the Board to receive and examine Whistleblowing notifications in accordance with the company's specific instructions.

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