We ask the Employment Fund’s managers and their related parties according to the Market Abuse Regulation to comply with the instructions on this page when declaring business transactions.
Declarations must be made to the Employment Fund and the Financial Supervisory Authority within three days of a transaction.
In light of the Employment Fund’s obligation to publish the business transactions of managers, we recommend declaring transactions to the Employment Fund in a free-form manner on the day when they take place. The full declaration is made to the Employment Fund within two days of the transaction.
1. Notify the Financial Supervisory Authority about transactions in their e-services
Instructions for submitting a notification are available at the Financial Supervisory Authority’s website.
The following information is required on the declaration:
|The Employment Fund’s LEI
|The ISIN codes of the Employment Fund’s bonds
|FI4000440227 (maturity date 6/16/2023)
FI4000440276 (maturity date 6/16/2027)
|Generated on the form automatically (there is no need to fill in this section)
2. You can download the completed form in PDF format from the e-service before submitting it to the Financial Supervisory Authority. Send the completed form as an email attachment to the Employment Fund.
Do not send the form by post due to the short deadline (three working days).
Sending the form to the Financial Supervisory Authority:
Go to https://asiointi.finanssivalvonta.fi/en/ and notify the Financial Supervisory Authority about the transactions in the e-service.
Sending the form to the Employment Fund:
Download your completed form in PDF format from the Financial Supervisory Authority’s e-service. Send the form as an attachment to a secure email to firstname.lastname@example.org
In the email, provide your phone number through which you can be contacted if we have any questions about the notification.
In the event of any problems, contact email@example.com.
The Employment Fund will publish declarations as stock exchange releases as soon as it receives them.
The transaction declarations made by managers and their related parties since 3 July 2016 are available for viewing in our archive of stock exchange releases.
For more information about the regulations concerning transaction declarations by managers and their related parties, see the website of the Financial Supervisory Authority.
The Employment Fund complies with the insider guidelines approved by the Board of Directors on 25 October 2022. The Employment Fund has issued publicly quoted bonds. As a result, the Employment Fund is responsible for organising insider administration in accordance with the legislation.
The purpose of these insider guidelines is to harmonise and clarify the processing of insider matters in the Employment Fund and to prevent abuses. These guidelines apply to all persons employed by the Employment Fund and all persons in its managerial positions. In addition, these guidelines are applied to those acting on behalf or for the account of the Employment Fund when they perform tasks through which they have access to inside information.
Inside information refers to information of a precise nature that has not been made public, which is directly or indirectly related to one or several issuers or financial instruments and which, if disclosed, would be likely to have a significant effect on the price of said financial instruments or financial derivatives linked to them.
Inside information may include information related to the Employment Fund or one or more of its financial instruments. Inside information may include, for example:
Inside information must be made public as soon as possible. Inside information must be made public and kept on the Employment Fund’s website for at least five years.
The Employment Fund may, on its own responsibility, decide to postpone the publication of inside information if all the following conditions are met:
Abuse of inside information (for example, insider dealing or advising on it) and illegal disclosure of inside information are prohibited.
A person who possesses inside information must not
Breaching the insider provisions may result in administrative or criminal sanctions against both the Employment Fund and the persons who have breached the insider provisions.
A market sounding comprises the communication of information, prior to the announcement of a transaction, in order to gauge the interest of potential investors in a possible transaction and the conditions relating to it such as its potential size or pricing, to one or more potential investors.
From time to time, the Employment Fund may have the need to map out investors’ interest in, for example, its financial instruments (such as a bond) before publication of a possible issuance. In such cases, the procedure specified in the insider guidelines is followed.
When the Employment Fund acts as a recipient of market sounding, it follows the procedures specified in the insider guidelines.
An insider means any person who possesses inside information, irrespective of the way in which the inside information was obtained. A person may also become an insider inadvertently and/or accidentally. All insiders must be entered in the insider list.
The Employment Fund and those acting on its behalf or for its account have an independent obligation to keep insider lists of persons referred to in the market abuse regulation who have access to inside information and who work for the Employment Fund on the basis of an employment contract or otherwise perform tasks through which they have access to inside information. The Employment Fund establishes an insider list for each individual project in which only the information of persons with access to that particular insider information is entered (project-specific insider lists). The Employment Fund does not maintain the insider list’s supplementary section listing permanent insiders, but only the project-specific lists are used.
The project-specific insider list must include all persons who have access to inside information and who work for the Employment Fund on the basis of an employment contract or otherwise perform tasks through which they have access to inside information.
A person entered on an insider list must be informed in writing of their entry on the list, of the resulting obligations and of the consequences of insider dealing and unlawful disclosure of inside information. Persons entered on a project-specific insider list in the Employment Fund are prohibited from all trading with the Employment Fund’s financial instruments and transactions related to them until the project expires or is published.
A project-specific insider list may be terminated once the project has been published or it has expired. Any published projects in which the disclosure of inside information has been postponed must be reported to the Financial Supervisory Authority without delay after the publication.
The trading practices of persons in the Employment Fund’s managerial positions must maintain confidence in the securities market. The reporting and publishing of transactions made by persons in managerial positions allows investors to monitor their holdings while, at the same time, supporting confidence in securities markets and increasing market transparency.
The Employment Fund must keep a list of persons in managerial positions and parties related to them (for example, spouses and children). A person is considered to be in a managerial position within the issuer if they are
With the criteria mentioned above, the Employment Fund has defined the following persons as persons working in managerial positions, who and whose related parties are subject to the special obligation to report transactions explained below:
Persons subject to the reporting obligation who are in managerial positions and their related parties have an independent obligation to report all transactions with the Employment Fund’s financial instruments to the Employment Fund and the Financial Supervisory Authority.
Persons in managerial positions and their related parties are obliged to report all transactions concerning the Employment Fund’s financial instruments made on their own account to the Employment Fund and the Financial Supervisory Authority. The reporting obligation applies to any transactions conducted on any marketplace or outside them.
The transactions exceeding the threshold of EUR 5,000 during the calendar year that have to be reported include:
Article 19(7) of the market abuse regulation and the Commission Delegated Regulation (EU) No 2016/522 supplemented by it define examples of transactions related to financial instruments that are covered by the reporting obligation. Transactions to be reported include:
Persons in managerial positions and their related parties are obliged to report transactions with the Employment Fund’s financial instruments to the Employment Fund and the Financial Supervisory Authority without delay and within three (3) working days of the transaction at the latest. The Employment Fund must publish the transaction within two (2) working days after receiving the above-mentioned transaction report.
The reporting obligation begins only when the total amount of EUR 5,000 has been reached during the calendar year. The threshold is calculated by adding up, without offsetting, all transactions made during the calendar year.
The information content of the report is regulated. The transactions are reported to the Financial Supervisory Authority through its electronic services. The report must also be sent to the Employment Fund by email at firstname.lastname@example.org.
The trading practices of persons in the Employment Fund’s managerial positions must maintain confidence in the securities market. A person in the Employment Fund’s managerial position must schedule their trading with the Employment Fund’s financial instruments in such a way that trading does not undermine confidence in the securities market, and, as a rule, transactions should not take place during, for example, a closed period.
Persons in the Employment Fund’s managerial positions and their related parties as well as other persons within the scope of the trading restriction imposed by the Employment Fund are always responsible for ensuring that their activities comply with the regulation laid down in the market abuse regulation, the provisions issued under it and the regulations given in the guidelines of the stock exchange.
Once a person has received inside information, they may not trade with the Employment Fund’s financial instrument during the project. The restriction will remain in force as long as the person is involved in the project in question or until the project has been appropriately terminated. The trading restriction remains in force until the end of the project, even if the employment or service relationship of the project-specific insider ends during the project.
For a person in the Employment Fund’s managerial position, directly or indirectly trading with the Employment Fund’s financial instrument for their own account or for the account of a third party is prohibited during a so-called closed period, regardless of whether the person has inside information at that time. The closed period lasts for 30 days before the publication of the statutory interim financial report or the financial statement release, including the date of the publication. If the financial statement contains material information not previously published in the financial statement release, the closed period also applies to the financial statement.
The closed period applies to a person in managerial position as defined above and to other persons involved in the preparation of financial reports for whom the Employment Fund has imposed a trading restriction. The closed period does not apply to the related parties of persons in managerial positions or the related parties of other persons subject to a trading restriction.
However, as regards natural persons related to persons in managerial positions, it should be noted that a person in a managerial position may not disclose inside information or otherwise confidential information on the content of future financial reviews to their related parties. In addition, it should be noted that a person in a managerial position may not, during a closed period, trade directly or indirectly with the Employment Fund’s financial instrument for their own account or for the account of a third party. It is therefore prohibited for persons in managerial positions to carry out transactions, for example, for the account of incompetent persons under guardianship, their own controlled corporation or the controlled corporations of incompetent persons under guardianship.
A person in a managerial position is also responsible for compliance with trading restrictions when the management of their securities is entrusted to another person, such as a portfolio manager.
The summary of this guideline is available on the Employment Fund’s public website. Everyone employed by the Employment Fund is personally responsible for ensuring that they comply with insider regulations and these insider guidelines and that they report the persons to whom they have disclosed inside information to be entered in the insider list. A person receiving inside information also has the obligation to report themselves to be entered in the insider list if they have not been notified of an entry being made in the insider list.
The Employment Fund ensures that persons on insider lists and persons subject to a trade restriction and a reporting obligation recognise their position and its impacts.
The Employment Fund has a person responsible for insider issues who carries out the duties of the Employment Fund’s insider administration.
It is the responsibility of persons in managerial positions to keep the information concerning them and their related parties up to date. In addition, the Employment Fund annually verifies the information to be reported by persons in managerial positions.
The Financial Supervisory Authority acts as the supervisory authority in insider matters regulated by the market abuse regulation. Under the Act on the Financial Supervisory Authority (878/2008), the Financial Supervisory Authority may impose, for instance, a fine as an administrative sanction on those who violate the market abuse regulation’s provisions on, for example, keeping an appropriate insider list and reporting obligations.
Chapter 51, sections 1–2 of the Criminal Code (39/1889) contains provisions on the abuse of inside information and aggravated abuse of inside information. The provisions of the Criminal Code apply if the act is committed intentionally or through gross negligence.
As a result of a breach of these guidelines, the Employment Fund may impose a disciplinary sanction on the offender, such as a written warning or, depending on the nature of the breach, even terminate the person’s employment relationship. If necessary, the Employment Fund may also report the breach to the Financial Supervisory Authority or the Police.
The Employment Fund must have a procedure by which persons employed by the Employment Fund can report a suspected breach of financial market provisions and regulations through an independent channel. The Employment Fund's reporting channel is the Employment Fund’s anonymous whistleblowing system.