Insider guidelines

Aspiro complies with the insider guidelines of the Nordic Exchange.

Aspiro’s internal insider recommendation was latest updated in accordance to the new insider regulations that came into force on 1 July 2005. The recommendation are published and distributed throughout the company.

The insider register is publicly available and is maintained by the Swedish Finansinspektionen

Parties in the following positions have insider status in Aspiro:

  • Board members or deputy Board members of Aspiro or of the Boards of Aspiro’s subsidiaries;
  • The Chief Executive Officer, and where appropriate, Chief Operating Officer of Aspiro or Aspiro’s subsidiaries;
  • The Chief Financial Officers of Aspiro or Aspiro’s subsidiaries;
  • Auditors and deputy auditors;
  • Executives in the accounting and finance function;
  • Executives in the corporate communications function;
  • Other executives considered to have insider status in the company.

Persons that holds an insider position within Aspiro
 
All employees of Aspiro group companies are recommended to apply the insider recommendation and should conduct themselves as if they had insider status when buying and selling Aspiro shares, even if they do not need to notify the Swedish Financial Supervisory Authority.

Briefly, Aspiro’s insider recommendation implies the following:

  •  The obligation for all parties with insider status to notify the Swedish Financial Supervisory Authority of their own and closely related parties’ holdings of shares in Aspiro and changes to such holdings, using the forms intended for such purpose supplied by the Swedish Financial Supervisory Authority. Copies of notifications should be
    submitted to the Head of Corporate Communications simultaneous with submission to the Swedish Financial Supervisory Authority.
  • Prohibition of buying or selling Aspiro shares without first receiving permission from the Head of Corporate Communications, CEO or Chairman;
  • A prohibition applies to buying or selling shares or other financial instruments in Aspiro for 30 days prior to - including the day of - the publication of interim or annual financial statements;
  • An obligation to report insider information.

Aspiro keeps a record of parties with access to insider information affecting the company on an ongoing basis in a logbook. This registration:

  • Identifies the party with access to insider information, the information in question, and when such party gained access to it;
  • Is updated as soon as circumstances change;
  • Is retained for five years;
  • Is submitted to the Swedish Financial Supervisory Authority on demand.

Download Aspiros Insider Recommendation


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