In its insider administration, Ahlstrom follows the Guidelines for Insiders issued by Helsinki exchange complemented by the Company’s own Insider Rules approved by the Board. The Company maintains its public and company-specific insider registers in the SIRE system of Euroclear Finland Ltd.
In accordance with the law, Ahlstrom’s public insiders include the members of the Board, the CEO and his Deputy, auditors, the members of the EMT as well as the General Counsel. Ahlstrom’s register of company-specific permanent insiders includes individuals who are defined by the Company and who regularly possess insider information due to their position in the Company.
According to Ahlstrom’s Insider Rules, persons listed as permanent insiders shall not in any case trade in the Company’s securities after the end of each calendar quarter until the day after the publication of the (quarterly) interim report or annual result (“Closed Window”). The Closed Window shall, however, always include at least the three weeks immediately preceding the publication of the (quarterly) interim report or annual result and the date of publication of such report.
In 2016, the Closed Window periods are: January 1-29 related to the financial statements bulletin 2015, April 1-28 related to the January-March 2016 interim report, July 1 – August 3 related to the January-June 2016 interim report, and October 1-28 related to the January-September 2016 interim report.
The Company’s legal function also maintains a project-specific insider register when required by law or regulations. Project specific insiders are prohibited from trading in the Company’s securities until the termination of the project.