12. INSIDE INFORMATION

Published : June 14, 2016  /  Updated : August 12, 2019

12. Inside information

Stora Enso expects all its employees to act in the way required of Insiders. All unpublished information relating to Stora Enso’s present and future business operations shall be kept strictly confidential.

It is illegal in many countries to use Inside Information to make a profit, or avoid a loss, in the trading of public securities, including Stora Enso securities or the securities of other public companies, where there is likelihood that a reasonable investor would consider the Inside Information important in making an investment decision. All Stora Enso employees are prohibited from disclosing Inside Information improperly, regardless of how that information was obtained. Inside Information 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Anyone who has unpublished information that is likely to affect Stora Enso share price is an Insider. The misuse or unlawful disclosure of Inside Information is always prohibited and may be sanctioned by law regardless of how Inside Information has been obtained or of the position of the person possessing Inside Information.

Insider lists

When a large project such as a merger or acquisition is under preparation, persons who are involved in the project and receive Inside Information shall be recorded in project-specific Insider lists that are established when Inside Information 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 involve Inside Information but may nonetheless be of a sensitive nature.

Restriction on trading

It is not allowed to use Inside Information to gain economic benefit from securities transactions for oneself or for a third party. It is therefore important to ensure that no transactions with Stora Enso securities are carried out at a time when the manager or employee is in possession of Inside Information.

The prohibition may also concern the trading in securities of other companies of which Stora Enso employees possess Inside Information, e.g. a listed company that is Stora Enso’s 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.

Stora Enso’s recommendation is that the Company shares are bought as long-term investments. If you are unsure whether you can trade with Company securities, you may ask the General Counsel or Assistant General Counsel or person in charge of insider lists, whether in the opinion of the Company you are not allowed to trade. However, keep in mind that Insiders themselves are responsible for their transactions with Stora Enso’s securities.

Case studies and best practices

  • Read the “Stora Enso Insider Guidelines” or its equivalent for more detailed information.