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Proha complies with the Guidelines for Insiders issued by NASDAQ OMX Helsinki Ltd.

According to the Securities Market Act Proha’s permanent insiders are the members of the Board of Directors, the CEO and the auditor in charge. Other permanent insiders are people who, in their work, come into regular contact with information that has a relevant effect on the value of securities.

Proha Plc maintains an insider register at the SIRE system of Euroclear Finland Oy (previously the Finnish Central Securities Depository).

All insiders have received the insider guidelines of the company. The company follows documented procedures in the administration and non-disclosure of inside initiatives. The content of the guidelines for permanent insiders corresponds to the insider guidelines by the Helsinki Stock Exchange and which are based on a recommendation by the Helsinki Stock Exchange, the Central Chamber of Commerce and the Confederation of Finnish Industries and Employers.

The CFO of the company controls the observation of the insider guidelines by sending extracts of the information entered into the insider register for review to the insiders on a regular basis and by monitoring the observation of trading restrictions for insiders.

Proha’s permanent insiders are not allowed to trade securities issued by the company within a period of 30 days before the publication of the interim report and the financial statements. Trading with the company’s securities is also not allowed, if the insider is in the possession of unpublished inside information which may affect the value of the share.

 
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