Disclosure policy

In all of its communication, Partnera complies with the EU’s regulations, such as the Market Abuse Regulation (“MAR”), Finnish law, the guidelines of Nasdaq Helsinki Oy’s Nasdaq First North Growth Market Rulebook, the decrees and guidelines of the European Securities and Market Authority, and the Financial Supervisory Authority, as well as the company’s administrative principles and other internal guidelines.

The disclosure policy describes the most central operating principles and procedures according to which the company communicates with the capital markets and other parties. The company complies with the disclosure policy in all of its communication, including financial reporting.The company’s Board of Directors approved the disclosure policy on April 22, 2020, and it will be updated as necessary.

Core principles of communication and investor relations

The core principles of Partnera’s communication are consistency, precision, openness, honesty, activeness and impartiality. Partnera communicates both positive and negative matters consistently and simultaneously to all of its stakeholders. The aim is to support the real value creation of Partnera’s shares and possible other issued financial instruments of the company by conveying correct, sufficient and relevant information to the capital markets about the company’s activities, operating environment, strategy, objectives and financial situation. Partnera discloses information based on the disclosure obligation as soon as possible.

Partnera will not comment on market rumors, speculation, the company’s share price development, or the actions of competitors or customers, unless it is necessary in order to correct a clearly erroneous or misleading information. The company may release an announcement in order to correct clearly erroneous or misleading information that is likely to have a significant impact on the value of Partnera’s financial instruments.

The company meets and actively seeks dialogue with representatives of capital markets and the media, and will respond without unnecessary delay to queries from the company’s shareholders, investors, analysts and the media. The relevant matters handled in meetings have already been disclosed earlier. Partnera will not favor individual analysts or share analysts’ reports with investors.

Areas of responsibility

Partnera’s CEO is responsible for communication with the company’s investors. Partnera’s statements will generally be given by the CEO, who is primarily responsible for contact with investors, shareholders, analysts and the media. The company’s CFO will act as the CEO’s deputy. The CEO or other members of the company’s management team will not comment on matters pertaining to Partnera’s Board of Directors. The Board of Directors is mainly represented by the Chairman of the Board.

Communication channels

Partnera’s main, up-to-date information channel is the company’s website at www.partnera.fi. All essential information regarding the company will be published in Finnish, using an official content management system, to Nasdaq Helsinki, key media and the company’s website at www.partnera.fi.

Languages of reporting and publication

The company’s official language of reporting is Finnish.

Company announcements

Through company announcements, Partnera discloses inside information pertaining to the company, as well as other information that must be notified as a company announcement according to currently valid regulations and the Nasdaq First North Growth Market guidelines, such as financial reports, the summons and decisions of the General Meeting, changes in the Board of Directors or management, as well as of the auditor or Certified Adviser, decisions on adopting a share-based incentive scheme, new shares or other financial instruments being offered, transactions between the company and persons closely associated with it that do not fall under the company’s regular business, managers’ transactions, and predictions and changes thereof.The company announcements are delivered to Nasdaq Helsinki and key media via an official content management system. Company announcements are available on the company’s website for at least five years after they are published.

Other announcements

News that does not include inside information or information that the regulations of Nasdaq First North Growth Market require to be disclosed, but which the company considers newsworthy or otherwise interesting to the company’s stakeholders, may be published as a press release or other form of announcement or news on Partnera’s website.

Financial reporting

Partnera publishes half-yearly reports, financial statement announcements, financial statements, annual reports and audit reports according to a previously announced annual schedule. The company publishes the disclosure dates of reports pertaining to financial information by means of a company announcement before the start of each fiscal year. The financial reporting schedule is also available on Partnera’s website. Financial reports are available on Partnera’s website for at least five years after they are published.

Quiet period and closed period

Partnera observes a quiet period of 30 days before the disclosure of the financial statement announcement and the half-yearly report. During this period, the company does not discuss the company’s profit or factors relating to it with capital market parties or media representatives. If some event during the quiet period requires immediate disclosure, Partnera will do so without delay, in accordance with the regulations pertaining to the disclosure obligation, and may comment on the event in question after its disclosure.

Partnera observes a 30-day closed period in accordance with the MAR, during which Partnera’s management and certain other personnel of the company and its subsidiaries who have access to the profit announcement information in its preparation phase are prohibited from conducting any transactions, directly or indirectly, on their own account or for the account of a third party relating, to Partnera’s financial instruments.

Managers’ transactions

Partnera discloses all transactions of managers and persons closely associated with them relating to Partnera’s financial instruments as a company announcement in accordance with the MAR, as notified without delay and within at most three working days of the transaction.