Insider Policy, Beijer Electronics Group AB (publ), (BEG)
The EU Market Abuse Regulation (MAR)1 of July 2016 is now in force for regulating insider information, insider registers and reporting changes to holdings of persons discharging managerial responsibility in listed companies.
Beijer Electronics Group AB’s Board of Directors has adopted this Insider Policy to supplement applicable legislation.
This Policy applies to the Board of Directors and all employees with access to insider information.
Insider regulations in brief
Pursuant to the MAR, BEG is liable for maintaining a register of all persons discharging managerial responsibility, and their related parties. Additionally, all these individuals must be informed of their obligations, which include a liability to report trading in BEG shares within three (3) calendar days, firstly to the Swedish Financial Supervisory Authority, and secondly, to BEG, as soon as the transactions reach a total value of € 5,000 in any calendar year.
BEG also maintains an internal insider register of individuals with access to insider information on the company, pursuant to recommendations issued by the Swedish Financial Supervisory Authority. This register should include information on all persons with access to insider information, as well as the type of information and timing of register updates. Persons included in the insider register are immediately informed of their inclusion, and the implications thereof.
There is also general prohibition of trading in BEG shares from 30 calendar days prior to the publication of interim or annual financial statements, termed the blackout period.
The Swedish Financial Supervisory Authority has issued guidance in its document Vägledning Börs- och MTF-bolag 2 (‘Guide for listed and MTF companies’), offering more detail.
Over and above applicable regulations, BEG applies the following rules to insider information and trading:
a) All employees included in the insider register, and persons discharging managerial responsibility and their related parties must report all trading in BEG shares (regardless of legally stipulated thresholds) to BEG’s Investor Relations function or CFO.
b) The period of prohibition of trading in BEG shares from 30 days prior to the publication of financial reports,known as the blackout period, also includes the day of publication.
c) Short-term trading in BEG shares is not permitted for employees included in the insider register, and persons discharging managerial responsibility, and their related parties. Short-term trading generally implies ownership for a period of less than one quarter.
The Board of Directors
Malmö, Sweden, 27 January 2017