Corporate Governance
Insider management
The company's insider administration complies with the Market Abuse Regulation (MAR) and Nasdaq Helsinki's rules, which are supplemented by the company's own insider policy.
Managers are not permitted to carry out transactions involving Easor financial instruments, either directly or indirectly, on their own behalf or on behalf of a third party, during a closed period of 30 calendar days prior to the publication of each Easor interim report or financial statements release. Easor applies a closed period between the end of each calendar quarter and the day following the publication of Easor's interim report or financial statements release ("Closed Window"). However, the Closed Window shall always include at least 30 calendar days prior to the publication of the interim report or financial statements release and the entire publication day of the report in question. The prohibition shall apply regardless of whether or not the person in question is in possession of inside information during this period.
Easor's CFO acts as the Insider Officer and is responsible for the overall organization of insider administration and compliance with requirements, including monitoring changes in applicable regulations. The Insider Officer is responsible for the administration and monitoring of compliance with the Market Abuse Regulation (EU No. 596/2014, "MAR") and the Insider Policy, including the maintenance of insider lists, supervision of insider matters, managers’ transactions, and notifications to the Finnish Financial Supervisory Authority (FIN-FSA) and other relevant parties, as well as organizing training and providing guidance.
Related-Party Transactions add
In accordance with the Corporate Governance Code and applicable legislation, the Company must assess and monitor transactions between the Company and its related parties and ensure that potential conflicts of interest are appropriately considered in the Company's decision-making. Easor maintains a list of the Company's related parties.
Related-party transactions are conducted on an arm's length basis, and relevant decisions are made in accordance with the Company's related-party policy. The CFO, authorised by the Board, or a person reporting to them, maintains an up-to-date list of natural and legal persons belonging to the Company's related parties. The Company's financial administration monitors related-party transactions based on accounting records, Board documents, and other available sources, and regularly queries management and key personnel regarding related-party transactions. In connection with quarterly reporting, financial administration processes ensure that related party transactions are appropriately reported in the related-party transaction monitoring list maintained for financial reporting. The tracking list is regularly submitted to the Board for information.
The Company has implemented decision-making processes for related-party transactions that are not part of the Company's ordinary course of business or are not conducted on an arm's length basis. As a general rule, all related party transactions must be reported in the notes to the financial statements, and significant related party transactions must also be reported in the business reviews. In addition, the Company discloses such related-party transactions as required by applicable law and the rules of Nasdaq Helsinki.
Insider lists add
Easor maintains a list of all persons who have access to inside information and who work for Easor under an employment contract or otherwise perform tasks through which they have access to inside information, such as advisors, accountants, or credit rating agencies. A list of permanent insiders is maintained for persons who are insiders with respect to all inside information due to the nature of their duties or their position. Permanent insiders, by definition, have continuous access to all inside information (including information on all of the company's insider projects). Permanent insiders are not added separately to each project-specific insider list.
A separate project-specific insider list is established and maintained for each project containing inside information. The project-specific insider list includes all company employees, management, and board members, as well as representatives of third-party companies, shareholders, and authorities who have knowledge of the insider project and/or access to project-specific inside information and/or work to implement the insider project. The project-specific insider list is not public.
