The purpose of Incap Corporation’s Insider Policy is to establish clear operating principles for the administration of inside information, the maintenance of insider lists and the notification of transactions by persons subject to the disclosure obligation. In addition to the Insider Policy, Incap Corporation complies with the Policy for Insiders by Nasdaq Helsinki Ltd. that entered into force on 4 December 2024, the EU Market Abuse Regulation (596/2014/EU, “MAR”) and related regulations, domestic regulation, particularly chapter 51 of the Finnish Criminal Code (39/1889) and the Finnish Securities Markets Act (746/2012), as well as the current provisions of the Finnish Financial Supervisory Authority’s rules and regulations on insider matters. The Insider Policy of Incap Corporation entered into force on 24 July 2025 by the decision of the Board of Directors of Incap, and it replaces Insider guidelines approved on 12 February 2018.
Incap maintains internal project-specific insider lists of persons to whom the company discloses project-specific inside information. Incap also maintains a list of the company’s permanent insiders. Incap’s permanent insiders include the members of the company’s Board of Directors, the President and CEO, members of the Management Team as well as persons who, by virtue of their position or duties in the company, have regular access to inside information (such as the secretary of the Board of Directors) as well as persons outside the company who work for the company and have regular access to inside information.
Trading by persons discharging managerial responsibilities at Incap is forbidden 30 days before the publication of a business review or an interim report, a half-year report, a financial statements bulletin or any other published financial report (closed window). If the financial statements contain material information not previously disclosed in the financial statements bulletin, such as future development prospects, the closed window also applies to the financial statements.
The restriction on trading ends one day after the said report is published. The trading restriction also applies to persons closely associated with persons discharging managerial responsibilities in Incap and persons participating in the preparation of the company’s financial reports.
An appropriate time for trading is within 28 days after the publication of a business review or an interim report, a half-year report, a financial statements bulletin or any other financial report, provided that the person does not at that time possess any other inside information, such as on a project under preparation.
Project-specific insiders are not permitted to trade with Incap’s financial instruments during said project. The trading restriction will remain in force until the information has been disclosed, or the project has expired.
Changes in the holdings of insiders are disclosed in stock exchange releases, which the company publishes in accordance with the MAR regulation.
Incap Corporation’s Insider Policy valid as from 24 July 2025
