UPM follows the Guidelines for Insiders of Listed Companies issued by Nasdaq Helsinki Ltd. The company’s Insider Policy, approved by the Board of Directors, complements applicable insider regulations and sets out guidelines for the company’s insiders and insider administration and for the persons discharging managerial responsibilities and their closely associated persons.
Organisation of insider administration
The company’s Chief Compliance Officer is in charge of the overall organisation of the company’s insider administration. UPM Insider Administration comprising of the General Counsel, Chief Compliance Officer, Group Legal Counsel responsible for securities markets compliance, Insider Administrator and a back-up person for the Insider Administrator is responsible for monitoring compliance with UPM Insider Policy, Market Abuse Regulation (MAR) and other applicable insider regulations and guidelines. UPM Insider Administration is also responsible for the ongoing supervision, management and administration of insider matters, including maintenance of insider lists, managers’ transactions, notifications to managers, FIN-FSA and other relevant parties, as well as provision of training and advice.
List of managers and closely associated persons
As required by MAR, the company maintains a list of persons discharging managerial responsibilities (managers) and their closely associated persons. These persons are required to notify UPM and the FIN-FSA of every transaction conducted on their own account relating to the financial instruments linked to UPM. Each manager and closely associated person is informed in writing of his/her position as such and related obligations.
At UPM, managers include the members of the Board of Directors, the President and CEO, the Chief Financial Officer and the Executive Vice Presidents of the business areas. Based on UPM’s governance structure, the above mentioned executives are deemed to comprise the senior executives of the company who have regular access to inside information relating to UPM and power to take managerial decisions affecting the future developments and business prospects of the company.