Investor relations

Insider management

The company complies with the EU Market Abuse Regulation ((EU) 596/2014 as amended, ”MAR”) and with the subordinate provisions issued pursuant thereto as well as with other applicable legislation and guidelines issued for Insiders.

The company’s Board of Directors has approved insider guidelines for the company. The guidelines describe the organisation of insider management, the practices for disclosing inside information, the management of insider lists, the obligation to report transactions and trading restrictions.

Organisation

The company’s person in charge of insider issues is responsible for the organisation of inside information management and for monitoring compliance with MAR, insider guidelines and other insider rules in force from time to time.

The tasks of insider management include inter alia maintenance of insider lists, notifications to Oslo Børs and internal guidance and advisory.

Primary insiders

The company maintains a list of primary insiders, i.e. persons discharging managerial responsibilities and persons closely associated with them. These persons are obliged to notify the person in charge and Oslo Børs of all transactions made on their behalf in connection with the financial instruments related to Nordhealth AS after the total amount of EUR 5,000 has been reached in transactions made during the calendar year. All persons discharging managerial responsibilities and persons closely associated with them are informed in writing of their position and responsibilities. The company publishes transactions made by persons discharging managerial responsibilities and persons closely associated with them related to the financial instruments of Nordhealth AS in accordance with the notifications received from them without delay and no later than within two business days of the transaction.

The company has defined the members of the Board of Directors, external Committee members, the CEO and the members of the Group Executive Committee as persons discharging managerial responsibilities.

Insider lists

The company maintains a project-specific insider list of company projects that constitute inside information. A project-specific insider list is created immediately when a decision is made to establish an insider project and delay disclosure of inside information. Project-specific insider lists are created by the Board of Directors or the CEO, and are maintained by the company’s insider management.

All persons, who have received inside information, will be listed in the project-specific insider list. A person listed on a project-specific insider list will be informed in writing of his / her entry on the list and the related obligations, prohibitions on dealing, disclosure, recommendation and inducement, sanctions and, at the end of the project, the end of the project and the termination of obligations.

Closed period

In accordance with MAR, the period during which the persons discharging managerial responsibilities are not allowed to trade in Nordhealth AS’s financial instruments prior to the publication of the company’s half-year report, quarterly information on the company’s result, and yearly financial statements release, is 30 days i.e. so-called closed period.

Company-specific trading restriction (extended closed period)

The closed period also applies to persons who participate in the preparation of the half-year reports and financial statements and other persons as defined by the company, i.e. so-called extended closed period. Extended closed window means that trading in the company’s financial instruments is strictly prohibited for persons covered by the extended closed period 30 days prior to the publication of the company’s half-year report, quarterly information on the company’s result, and yearly financial statements release.