12. Inside information
expects all its employees to act in the way required of . All unpublished information relating to present and future business operations shall be kept strictly confidential.
It is illegal in many countries to useto make a profit, or avoid a loss, in the trading of public securities, including securities or the securities of other public companies, where there is likelihood that a reasonable investor would consider the important in making an investment decision. All employees are prohibited from disclosing improperly, regardless of how that information was obtained. can be obtained at work, in meetings, at seminars or by accident, such as overhearing someone else’s conversation.
Adhering to the insider regulations is always a personal responsibility.
Anyone who has unpublished information that is likely to affectshare price is an . The misuse or unlawful disclosure of is always prohibited and may be sanctioned by law regardless of how has been obtained or of the position of the person possessing .
When a large project such as a merger or acquisition is under preparation, persons who are involved in the project and receiveshall be recorded in project-specific lists that are established when arises. The General Counsel or the Assistant General Counsel will decide case-by-case in which projects such a register shall be established. Persons included in a project-specific register are informed by letter or e-mail.
In addition to insider lists, also other confidentiality lists may be used for the purpose of controlling the flow of information regarding projects that do not involvebut may nonetheless be of a sensitive nature.
Restriction on trading
It is not allowed to useto gain economic benefit from securities transactions for oneself or for a third party. It is therefore important to ensure that no transactions with securities are carried out at a time when the manager or employee is in possession of .
The prohibition may also concern the trading in securities of other companies of whichemployees possess , e.g. a listed company that is counterparty in a merger or acquisition. Persons entered into such a project-specific insider list are always prohibited from trading for as long as the project continues.
recommendation is that the shares are bought as long-term investments. If you are unsure whether you can trade with securities, you may ask the General Counsel or Assistant General Counsel or person in charge of insider lists, whether in the opinion of the you are not allowed to trade. However, keep in mind that themselves are responsible for their transactions with securities.
Case studies and best practices
- Read the “Stora Enso Insider Guidelines” or its equivalent for more detailed information.