The Guidelines contain regulations governing inside information, prohibition against abuse and improper disclosure of inside information, disclosure of insider information, public insider registers, non-public lists of insiders, list of executives as well as reporting and disclosure of transactions, trading restrictions applicable to insiders as well as insider management. The Guidelines also cover restrictions imposed on relevant persons and the organisation of supervision of compliance with the restrictions.
In addition, OP Corporate Bank plc and OP Mortgage Bank as OP Financial Group’s issuers of securities have separate guidelines for insiders and insider trading, which they apply in their role as issuers. These companies have a list of the executive insiders of the issuer. In addition, those who are considered to have ongoing access to all inside information on securities issued by OP Corporate Bank plc are included in the permanent non-public insider list of OP Corporate Bank plc.
The Guidelines for Insiders and Insider Trading are based on laws governing securities markets, such as the Market Abuse Regulation, regulations issued by the Finnish Financial Supervisory Authority, Guidelines for Insiders of Listed Companies issued by Nasdaq Helsinki, and Trading Instructions for FFI Member Organisations.
The Guidelines are aimed at fostering stock market players’ trust in OP Financial Group, OP Corporate Bank plc and OP Mortgage Bank.
OP Legal Services maintains public insider registers of OP Financial Group entities, registers of relevant persons and, in respect of OP Corporate Bank plc and OP Mortgage Bank as issuers of securities, the lists of executives and, in respect of OP Corporate Bank plc, the list of company-specific permanent insiders. Such maintenance is organised through the SIRE system maintained by Euroclear Finland Ltd and through OP Financial Group’s SIPI system.
Whenever necessary, OP Financial Group companies keep project-specific insider lists.
As credit institutions, OP Financial Group’s member bank operations include participation in securities trades performed by clients or in other transactions related to securities. In connection with financing arrangements or as part of the bank’s other ordinary operations, member banks and their executives and salaried employees may also receive inside information on client companies. For the abovementioned reasons, among other things, member banks and their executives and salaried employees are subject to insider regulation as referred to in the applicable law.
Training in insider issues is available on a regular basis. Such training will particularly take place at times following changes in insider guidelines.
Anyone has the right to access the public register of insider holdings and receive extracts and copies of the information in the register against a charge. However, a natural person’s personal ID code and address and the name of a natural person other than the insider are not publicly available. Information included in the register of the relevant persons, the list of permanent insiders or the list of project-specific insiders is not publicly available, unlike that included in public insider registers. Extracts from and copies of the public insider register can be ordered from OP Legal Services, Legal Services for Wealth Management Private and SME Customers. Written requests for such information specifically describing the information should be submitted to:
OP Legal Services
Wealth Management Legal
P.O. Box 1068
00013 OP