Fortum observes the Guidelines for Insiders issued by NASDAQ OMX Helsinki. Fortum’s own internal insider rules are regularly updated and made available to all permanent insiders, as well as to all employees of Fortum. The company arranges training on insider rules. Fortum maintains a public insider register of persons obliged to declare insider holdings, as required under the Securities Markets Act, and a non-public company-specific insider register of such parties who receive inside information.
Public insider register
Permanent insiders registered in the public insider register are personnel representatives, members of the Board of Directors, the President and CEO, the auditor and employee of the audit organisation who has the principal responsibility for the audit of the company, as well as members of the Fortum Management Team as well as certain other executives.
In accordance with the Securities Markets Act, also the securities holdings of the insider’s next-of-kin, who share a household with the insider, have been public at Fortum as of 1 January 2006. The shareholdings of Fortum’s insiders registered in the public insider register is available on our web site.
Company-specific insider register
Permanent insiders registered in Fortum’s companyspecific register are persons who, by virtue of their position or duties, may regularly receive inside information on the company. The company-specific register also contains information on such persons who obtain inside information by, for example, working for the company under a separate consulting contract.
Trading of company shares
All permanent insiders shall time the trading of shares and related securities issued by the company so that the trading does not undermine confidence in the securities markets. It is recommended that the permanent insiders acquire shares and related securities issued by the company as long-term investments. The permanent insiders may not trade in shares and related securities issued by the company within 30 days prior to the publication of interim reports and financial statements. When the publication of the interim report or the financial statements takes place more than 30 days after the end of the financial period, the closed window for trading begins at the end of the financial period.
Internal supervision of insider affairs
The company regularly monitors the trading of permanent insiders based on the information held in the register of the Euroclear Finland Ltd. The company may, on a case-by-case basis, supervise the trading of shares and related securities of its permanent insiders more thoroughly, for example, if a permanent insider trades in large volumes of shares and related securities or the trading of shares and related securities is continuous. In addition, the company supervises compliance with insider rules by asking the public insiders to check the accuracy of the information given by them each year.
The co-ordination and control of insider affairs are included in the responsibilities of Fortum’s General Counsel. The executive of each function or unit monitors the insider affairs in his/her own organisation.