Insider administration
On 29 April 2022, the Board of Directors of VR-Group Plc approved insider guidelines and trading guidelines, according to which the person in charge of insider issues is the Chief Legal Officer and the person in charge of insider lists is the Compliance Officer. The Group Treasurer is responsible for managing disclosures concerning trading restrictions and transactions.
Insider administration
- is responsible for training and communication concerning insider issues;
- is responsible for drawing up and maintaining insider lists and submitting them to the Financial Supervisory Authority upon request;
- maintains a list of persons discharging managerial responsibilities and their related parties;
- is responsible for the monitoring and follow-up of insider issues;
- ensures that persons discharging managerial responsibilities, the persons included in insider lists, and persons who are in the informational core of the company recognise their position and its effects; and
- organises an annual review of information subject to disclosure for persons discharging managerial responsibilities and their related parties.
Project-specific insider lists include all persons who have access to inside information or who otherwise perform tasks based on which they have access to inside information, including external advisors, public authorities and other parties with information about the project in question. VR-Group Plc also maintains a list of persons discharging managerial responsibilities and their related parties. The persons discharging managerial responsibilities are defined as the members of the Board of Directors and the Supervisory Board, the President and CEO, and the Group Management Team.
The closed period begins 30 calendar days before the publication of each interim/half-year report or annual financial statements of VR-Group Plc and concludes at the end of the publication date of the interim/half-year report or annual financial statements. Persons discharging managerial responsibilities at VR-Group Plc are not allowed to engage in direct or indirect trading in VR-Group Plc’s financial instruments during the closed period. This applies regardless of whether or not the person discharging managerial responsibilities has access
to inside information during the closed period. Persons discharging managerial responsibilities are also not allowed to engage in direct or indirect training in VR’s financial instruments on behalf of a third party during the closed period.
