Insider administration

Insider administration

Lemonsoft complies with the EU Market Abuse Regulation ((EU) 596/2014 as amended, “MAR”) and with the lower-level regulation issued pursuant thereto as well as with the Finnish Securities Markets act (746/2012 as amended, “SMA”), regulation and guidelines issued by the competent Authorities, and Nasdaq First North Growth Market Rulebook and the guidelines for insiders by Nasdaq Helsinki Ltd.

Lemonsoft has appointed an insider manager, who is responsible for maintaining the company’s insider lists, enforcing trading restrictions and the obligation to report and disclose transactions, internal communication and training related to insider matters, and supervision of insider matters. The company has internal procedures for publishing insider information, possibly postponing the disclosure of insider information and maintaining project-specific insider lists.

Managers’ transactions
The Board of Directors has defined the members of the company’s Board of Directors, the President and CEO, the members of the Management Team and the M&A Manager as persons in management positions. The directors and their close associates shall report their transactions with the company’s financial instruments or their derivatives without delay and no later than three business days after the execution of the transaction.

Notifications are made using the Financial Supervisory Authority’s electronic form and sent to the company by e-mail to johdonkaupat@lemonsoft.fi and to the Financial Supervisory Authority using a secure e-mail connection https://securemail.bof.fi to address johdonkaupat@finanssivalvonta.fi.

Lemonlight shall publish the transaction announcements made by the managers and their closely associated persons in accordance with Article 19 of the MAR in a company release without delay and no later than two (2) business days after receiving the notification.  The company complies with the trading restriction on managers under Article 19 (11) of the MAR Regulation (closed period) of 30 days before the announcement of an interim financial report or a year-end report.

Silent period and closed window
The publication of periodic financial reports is preceded by a silent period which commences 30 days before the publication date of the financial report. During the silent period, the company shall not comment on the company’s business prospects, financial results or estimates in any way. During this period, Enersense’s representatives shall not meet with shareholders, investors, analysts or other market representatives or the financial media to comment on matters related to the company’s financial condition or market or business outlook.

Lemonsoft complies with the MAR 30-day closed window, during which time Lemonsoft executives and other Lemonsoft employees involved in the preparation of earnings report may not buy or sell securities issued by Lemonsoft.