Insider management

Gofore Plc complies with the EU Market Abuse Regulation ((EU) No 596/2014, “MAR”) and its supplemented Nasdaq Helsinki Ltd’s guidelines for insiders in force from time to time. Gofore Plc’s Board of Directors has approved insider guidelines for the company. The guidelines describe the organisation of insider management, the practices for disclosing inside information, the management of insider lists, the obligation to report transactions and trading restrictions.

Organisation
Gofore Plc’s person in charge of insider issues is responsible for the organisation of inside information management and for monitoring compliance with MAR, insider guidelines and other insider rules in force from time to time.

The tasks of insider management include maintenance of insider lists, issuance of trading permits, notifications to senior managers and the Financial Supervisory Authority, and internal guidance and advisory.

Persons discharging managerial responsibilities
Gofore Plc maintains a list of persons discharging managerial responsibilities and persons closely associated with them. These persons are obliged to notify Gofore Plc and the Financial Supervisory Authority of all transactions made on their behalf in connection with the financial instruments related to Gofore Plc after the total amount of EUR 5,000 has been reached in transactions made during the calendar year. All persons discharging managerial responsibilities and persons closely associated with them are informed in writing of their position and responsibilities. Gofore Plc has the information included in the list of closely associated persons regularly reviewed with the respective persons discharging managerial responsibilities. Gofore Plc publishes transactions made by persons discharging managerial responsibilities and persons closely associated with them related to the financial instruments of Gofore Plc in accordance with the notifications received from them without delay and no later than within three business days of the transaction.

Gofore Plc has defined the members of the Board of Directors, the CEO and the members of the Group Executive Management Team as persons discharging managerial responsibilities.

Insider lists
Gofore Plc has decided not to establish a list of permanent insiders.

Gofore Plc maintains a project-specific insider list of company projects that constitute inside information. A project-specific insider list is created when a decision is made to establish an insider project and delay disclosure of inside information. Project-specific insider lists are created by the Board of Directors or the CEO, and are maintained by Gofore Plc’s insider management.

All persons, who have received inside information, will be listed in the project-specific insider list. A person listed on a project-specific insider list will be informed in writing of his / her entry on the list and the related obligations, prohibitions on dealing, disclosure, recommendation and inducement, sanctions and, at the end of the project, the end of the project and the termination of obligations.

Closed period
In accordance with the MAR, the period during which the persons discharging managerial responsibilities are not allowed to trade in Gofore Plc’s financial instruments prior to the publication of the company’s half-year report, quarterly information on the company’s result, and financial statements release, is 30 days i.e. so-called closed period. The closed period ends on the second day after the publication of the company’s half-year report, quarterly information on the company’s result, and financial statements release.

Company-specific trading restriction (extended closed period)

In accordance with the guidelines for insiders of Nasdaq Helsinki Ltd, the closed period also applies to persons who participate in the preparation of the half-year reports and financial statements and other persons as defined by the company, i.e so-called extended closed period. Extended closed window means that trading in the company’s financial instruments is strictly prohibited for persons covered by the extended closed period 30 days prior to the publication of the company’s half-year report, quarterly information on the company’s result, and financial statements release, and ends on the second day after the publication of the results.

Further information:
For more information on insider guidelines, please contact Gofore Plc’s person in charge of insider issues: Kalle Mäki, kalle.maki@gofore.com, tel. +358 40 7028 471