Atria complies with Nasdaq Helsinki Ltd’s Guidelines for Insiders. In addition, Atria’s Board of Directors has confirmed the insider guidelines for the company, which supplement other insider regulations and provide guidance on insiders and insider administration. The
company’s insider guidelines have been distributed to every member of the company’s personnel in a senior management position and those involved in preparing financial reports, as well as being made available on the company’s intranet.
The Market Abuse Regulation ((EU) No. 596/2014) has been applied since 3 July 2016. Atria has not established a permanent insider register and insider information is managed through project-specific insider lists, which are established and maintained as needed. All projectspecific insiders are informed in writing of their insider status and given appropriate insider guidelines.
Atria has determined that the members of the Board of Directors, members of the Supervisory Board, the CEO, the CFO and the Deputy CEO satisfy the definition of personnel in senior management roles whose details must be reported. The company maintains a list of the personnel in senior management roles and their related parties.
The company maintains a register of the senior management whose details must be reported and their related parties and, where applicable, Atria’s project-specific insiders. The company’s legal department and CFO monitor compliance with the insider guidelines.
Personnel in senior management positions and personnel involved in preparing financial reports have a restricted entitlement to enter into transactions involving the company’s financial instruments: these personnel may not trade in the company’s shares 30 days
before the publication of an interim report or financial statement release and, if there are more than 30 days between the end of the review period and the publication of the report/release, during this period.
Due to the implementation of the Regulation of the market abuse (EU No. 596/2014, “MAR”) since the 3rd of July 2016, we no longer update the Insider Register at our website.