Under the EU Market Abuse Regulation (EU) No 596/2014 (“MAR”), applicable as from July 3, 2016, members of the Nokia Board of Directors and the Group Leadership Team have been identified as 'persons discharging managerial responsibilities ' at Nokia. The persons discharging managerial responsibilities as well as persons closely associated with them, are required, after the threshold of EUR 5 000 has been reached within a calendar year, to report to Nokia and the Finnish Financial Supervisory Authority (the “FIN-FSA”) within three (3) business days from the transaction every transaction conducted on their own account relating to the shares or debt instruments of Nokia or to derivatives or other financial instruments linked thereto. Please find below instructions on how to report transactions.
NOTE! Due to the strict time limit of three (3) business days allowed for the reporting and related disclosure, we kindly ask you to report the transaction(s) as soon as possible after the transaction, and in no case later than three (3) business days after the transaction was executed.
NOTE! In case Nokia Corporation has been identified as ‘a closely associate person’ of a person discharging managerial responsibilities in your company, please send the related notification to email@example.com.
Reporting transactions in Nokia securities
- Please use the form provided by the FIN-FSA which is here.
- For the purposes of filling out the form, please note the following details:
- Nokia Corporation’s LEI number: 549300A0JPRWG1KI7U06
- Nokia share’s ISIN code in Nasdaq Helsinki and in Euronext Paris: FI0009000681
- Nokia ADRs ISIN code: US6549022043
- Notification reference: generated automatically, so there is no need to insert this
- Once completed, please send the form as an email attachment to Nokia at firstname.lastname@example.org and to the FIN-FSA through https://securemail.bof.fi to the address email@example.com within three (3) business days from the transaction. Please provide also your phone number in case Nokia needs to contact you regarding the form.
- Nokia is required to publish the information provided to it, through a stock exchange release within three (3) business days from the transaction.
List of financial instruments in scope of the obligation
The below list of financial instruments is provided for reference only and as the definition of ‘financial instrument’ in the Market Abuse Regulation is very broad, persons discharging managerial responsibilities as well as persons closely associated with them should not rely on this list as exhaustive or definitive, but familiarize themselves with the applicable laws and regulations, and with point (a) of Article 19(1) of MAR and with point (15) of Article 4(1) of Directive 2014/65/EU in specific.
- Nokia’s shares, listed in Nasdaq Helsinki and Euronext Paris;
- Nokia’s American depositary shares, evidenced by American depositary receipts, listed in New York Stock Exchange;
- Nokia’s debt instruments;
- Derivatives linked to Nokia shares or debt instruments;
- Other transferable Nokia securities;
- Money-market Nokia instruments;
- Units in collective investments undertakings, in case Nokia’s weighing is more than 20%;
- Options, futures, swaps, forward rate agreements and any other derivative contracts relating to Nokia securities, interest rates or yields or any other derivative instruments, financial indices or financial measures;
- Derivate instruments for the transfer of credit risk and involving Nokia;
- Financial contracts for differences.
List of transactions in scope of the obligation
- acquisition, disposal, short sale, subscription or exchange;
- acceptance or exercise of a stock option, including of a stock option granted to managers or employees as part of their remuneration package, and the disposal of shares stemming from the exercise of a stock option;
- entering into or exercise of equity swaps;
- transactions in or related to derivatives, including cash-settled transaction;
- entering into a contract for difference on a financial instrument of the concerned issuer or on emission allowances or auction products based thereon;
- acquisition, disposal or exercise of rights, including put and call options, and warrants;
- subscription to a capital increase or debt instrument issuance;
- transactions in derivatives and financial instruments linked to a debt instrument of the concerned issuer, including credit default swaps;
- conditional transactions upon the occurrence of the conditions and actual execution of the transactions;
- automatic or non-automatic conversion of a financial instrument into another financial instrument, including the exchange of convertible bonds to shares;
- gifts and donations made or received, and inheritance received;
- transactions executed in index-related products, baskets and derivatives, insofar as required by Article 19 of Regulation (EU) No 596/2014;
- transactions executed in shares or units of investment funds, including alternative investment funds (AIFs) referred to in Article 1 of Directive 2011/61/EU of the European Parliament and of the Council (4), insofar as required by Article 19 of Regulation (EU) No 596/2014;
- transactions executed by manager of an AIF in which the person discharging managerial responsibilities or a person closely associated with such a person has invested, insofar as required by Article 19 of Regulation (EU) No 596/2014;
- transactions executed by a third party under an individual portfolio or asset management mandate on behalf or for the benefit of a person discharging managerial responsibilities or a person closely associated with such a person;
- borrowing or lending of shares or debt instruments of the issuer or derivatives or other financial instruments linked thereto.
Nokia’s obligation to maintain and update public insider register in accordance with the Finnish Securities Market Act, will end on July 2, 2016. According to Finnish law, the register is required to be kept publicly available 12 months after that date. The below register will be frozen as per July 2, 2016 and any changes to the information thereafter will not be reflected in the table.