Neste Oil complies with the Insider Guidelines of NASDAQ OMX Helsinki Ltd. that came into force as of 9 October 2009. The Company has also approved its own Guidelines for Insiders, which are stricter in some areas. The Company’s closed window, for example, exceeds minimum NASDAQ OMX Helsinki requirements.
The Company’s Guidelines for Insiders are updated regularly and are available to all personnel. The Company arranges training on insider guidelines for personnel and expects that its guidelines are followed. The Company supervizes compliance with insider guidelines by checking disclosed information with those concerned annually. The Company’s General Counsel is responsible for the coordination and supervision of insider matters. The head of each common function or business area is responsible for supervising insider matters within his or her organization.
The members of the Board of Directors and the President & CEO, the Company’s main responsible auditor, and the members of the Neste Executive Board and its secretary have all been classified as insiders subject to a declaration requirement. The holdings of Company securities by such insiders are filed in the public Insider Register, which can be consulted at the Company’s web site. A public register is maintained in the insider register system of Euroclear Finland Oy (www.ncsd.eu).
The Company has also designated certain other executives, as well as certain individuals responsible for the Company’s finances, financial reporting, and communications, who receive inside information on a regular basis due to their position or duties, as permanent Company-specific insiders.
Permanent insiders may not trade in any Company securities during the period from the closing date of an interim or annual accounting period to the date of publication of the interim report or financial statements bulletin for that period. The minimum period concerned is always 28 days prior to the date of publication of the interim report or the financial statements bulletin (‘closed window’). The publication dates of interim reports and financial statements bulletins are shown in the financial calendar at http://nesteoil.com/investors.
Individuals who participate in the development and preparation of projects that involve inside information, such as mergers and acquisitions, are considered project-specific insiders. Such people are included in a separate register of Project-Specific Insiders maintained by the Company’s Legal Department.