Insider administration

Elo follows the insider trading regulations as stipulated by the Act on Pension Insurance Companies (TVYL). The purpose is to advance the public reliability of investment activities and to ensure the knowledge of personnel concerning insider trading regulations in order to prevent unintentional violations as well.

The insider regulations are applicable to Elo’s investment activities and any securities transactions being executed by personnel belonging to the company’s sphere of insiders. Individuals are included among the permanent insiders by virtue of their position or responsibilities. The insider regulations are also applicable to temporary insiders, who may receive project-specific insider information.

A permanent insider is obligated to request permission as regards trading in securities and to submit a declaration of holdings that specifies the number of purchased or sold securities and/or money-market instruments. Short-term trading is prohibited for all permanent insiders employed by Elo.

The Act on Pension Insurance Companies (354/1997; TVYL) gives anyone the right to receive extracts and copies of information in the register for a separately determined fee. Public information about Elo’s insiders is available, free of charge, from Euroclear’s NetSire service. However, the personal identification number and address of natural persons, as well as the names of natural persons other than insiders are not public. (TVYL Section 12 i, Paragraph 3)

Elo’s insider register is maintained by the Compliance Officer.