Insider administration

GRK complies with the insider guidelines issued by Nasdaq Helsinki Ltd. In addition, GRK’s insider policy, approved by the Board of Directors, complements the applicable insider regulations and defines the procedures concerning the company’s insider management and individuals involved in insider projects.

Organization

The overall organisation of GRK’s insider compliance is the responsibility of the Company’s General Counsel. GRK’s insider administration includes the General Counsel, who acts as the person in charge of insider matters, his or her deputy and the person who is responsible for maintaining the insider lists. 

Insider administration is responsible for monitoring compliance with the MAR, the company’s Insider Guidelines and other applicable insider regulations and instructions, as well as for providing training and guidance. Insider administration also handles the day-to-day management, supervision and administration of insider matters, including maintaining insider lists in a manner that meets regulatory requirements and ensures reliability. 

The company’s insider administration ensures that managers, persons receiving financial information and persons listed in the insider lists are aware of their position and its implications. This also includes internal communication about insider issues such as trading restrictions and notification requirements. The company’s communication organisation is responsible for publishing releases related to managers’ transactions. 

Notification obligation for managers and persons closely associated with them

Company’s managers and persons closely associated with them must notify all transactions in the company’s financial instruments carried out for their own account to both the company and the Finnish Financial Supervisory Authority without delay and no later than three (3) working days after the transaction has been carried out (T+3). The company shall publicly disclose such transactions by way of a stock exchange release without delay and within two (2) working days of receipt of the notification.  Company’s managers are members of the Board of Directors, the President and CEO and the CFO of the Company.

Closed Window

Managers or persons receiving financial information are prohibited from conducting transactions in the company’s financial instruments, either on their own account or for the account of a third party, directly or indirectly, during a closed window. Transactions may not be carried out during the 30-day period prior to the publication of the company’s financial statements release, interim report and half-yearly report and on the publication date (30+1). Should the financial statements contain material information that has not been published previously in the financial statements release, the closed window applies also to the financial statements. 

Project-specific Insiders

GRK has determined that it has no permanent insiders and does not maintain an insider list of permanent insiders. Persons on the project-specific insider list are subject to the trading restriction referred to in the company’s Insider Guidelines for the entire duration of the project. Persons on the insider list may not trade in the Company’s financial instrument even on the date of publication of the inside information. 

Reporting infringements

GRK has established a whistleblowing procedure that allows employees to report suspected violations of regulations and guidelines within the company through an independent reporting channel. The GRK’s whistleblowing channel, which is open to all, also allows for the reporting of suspected breaches of financial market rules and regulations. A link to reporting channel is available on the Company’s website and intranet, where the principles for handling reports are also described.  

You can access the notification channel here.