Aiforia complies with the Market Abuse Regulation (EU No 596/2014, as amended, "MAR"), the Market Abuse Directive (2014/57/EU, as amended), the Commission Delegated Regulation (2016/522/EU, as amended), the Commission Implementing Regulation (2016/347/EU and 2016/523/EU, as amended), Finnish legislation, in particular Chapter 51 of the Finnish Criminal Code (39/1889, as amended) and the Finnish Securities Markets Act's (746/2012, as amended), Nasdaq Helsinki Ltd's ("Nasdaq Helsinki") Guidelines for Insiders (as amended), Nasdaq First North Growth Market – Rulebook; and the rules and regulations of the Finnish Financial Supervisory Authority.
Insider guidelines include Aiforia Technologies Plc's procedures and guidelines for the company's personnel and management. Insider Policy has been approved by the Board of Directors.
Inside information means information of a precise nature relating directly or indirectly to one or more issuers or one or more financial instruments which has not been made public and which, if made public, would be likely to have a significant effect on the prices of the said financial instruments or on the prices of derivative financial instruments related thereto.
Regulation requires the issuer to disclose inside information as soon as possible, but exceptionally, provided that certain conditions are met, the issuer may also decide to delay the disclosure of inside information.
All persons who have received the inside information and who work for Aiforia under an employment contract or otherwise perform tasks through which they have access to inside information are recorded in the project-specific insider list.
In addition, Aiforia may maintain a supplementary section of the project-specific insider list comprising information on permanent insiders who have constant access to all inside information pertaining to the company. Permanent insiders are not separately recorded in project-specific insider lists. The project-specific insider list is not public.
Should inside information be provided to a party acting on behalf of or for the account of the company, or to a party performing tasks for the company (such as an advisor), the company shall enter in its project-specific insider list the name of that party and the name of the person in charge. An entity which has received inside information, and which acts on behalf of or for the account of the company, or performs tasks for the company, must maintain a project-specific insider list of all persons employed by it who possess inside information pertaining to the project. Aiforia has the right to access an insider list maintained by other entities on behalf of the company.
Aiforia shall inform a person recorded in the project-specific insider list in writing or otherwise in a verifiable way, for example by e-mail, of the entry in the project-specific insider list.
The managers shall not execute any transactions on their own account or for the account of a third party in the company's financial instruments prior to the announcement of the company's half-year report or financial statements bulletin during a period commencing 30 days before the announcement of the half-year report or the financial statements bulletin and ending at the end of the day subsequent to the publication day of such report (the "Closed Window").
Should the financial statements contain material information that has not been published previously in the financial statements bulletin, such as future prospects, the Closed Window applies also to the financial statements.
Managers and closely associated persons of the manager subject to the notification obligation
A manager or person closely associated with the manager must make the notification of a transaction promptly and no later than three business days after the date of the transaction. Aiforia publishes transaction notifications it receives in a company release without delay. Aiforia does not separately verify the accuracy of the notifications it receives.
Aiforia has set up a whistle-blowing procedure through which company's employees may report if there is reasonable doubt that a person employed by the company would have breached regulations and provisions concerning securities markets. If there is justified reason to suspect an infringement based on such report or if the infringement can be proven, the case shall be submitted to competent authorities for investigation.