Insider management

As securities issuer, OP MB has its own Insider Guidelines and Guidelines for Insider Trading as part of OP Financial Group’s Guidelines for Insiders and Insider Trading. The Insider Guidelines and Guidelines for Insider Trading for securities issuers contain regulations governing inside information, prohibition against abuse and improper disclosure of inside information, disclosure of inside information, public insider registers, lists of executives, reporting and disclosure of transactions, trading restrictions applicable to insiders and insider management. The Guidelines also cover the organisation of supervision of compliance with the restrictions. 

The Insider Guidelines and Guidelines for 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 and OP MB. 

OP Legal Services maintains public insider registers of OP Financial Group entities, registers of relevant persons, lists of company-specific permanent insiders and lists of executives. Such maintenance is organised through the SIRE system maintained by Euroclear Finland Ltd and through OP Financial Group’s SIPI system. 

When necessary, OP MB maintains project-specific insider lists. 

As a credit institution, OP MB’s 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 OP MB’s other ordinary operations, OP MB and its executives and salaried employees may also receive inside information on client companies. For the abovementioned reasons, among other things, OP MB and its 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 list of executives or the list of projectspecific 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’s Legal Services for Wealth Management unit. Written requests for such information specifically describing the information should be submitted to: 

OP Legal Services 
Legal Services for Wealth Management 
P.O. BOX 1068 
FI-00013 OP