Lemminkäinen observes the Market Abuse Regulation (EU 596/2014, "MAR") and the regulations and guidance given under it, including the insider guidelines of Nasdaq Helsinki Ltd. In addition, the company has issued supplementing internal Insider Rules. The company maintains its insider lists using Euroclear Finland Oy's Sire system.
Lemminkäinen has determined not to establish and maintain a list of permanent insiders. All persons involved in insider projects are included as project insiders in the project-specific insider lists.
Lemminkäinen has determined that the Management, whose transactions shall be notified, construes the members of the Board of Directors and the President and CEO. These persons and their closely associated persons are required to notify the Company and the FIN-FSA of every transaction conducted on their own account relating to the Financial Instruments of (or linked to) Lemminkäinen. In addition, MAR requires that Lemminkäinen discloses via stock exchange releases information on transactions by members of Management and their closely associated persons
The Management is prohibited to trade in the Financial Instruments of the Company after the end of each calendar quarter until the day after the announcement of the interim report or financial statements bulletin, as the case may (the "Closed Window"). The Closed Window shall, however, always include at least 30 calendar days immediately preceding the announcement of the interim report or financial statements bulletin, as the case may be, and the day of publication of such report.
In addition the company has persons having authorised access to unpublished financial result information. Lemminkäinen applies the closed window to such persons as well.
The person in charge of insider issues within Lemminkäinen is the General Counsel.
Updated 29 June 2016