Altia's Disclosure Policy
This Disclosure Policy was adopted by the Board of Directors (the "Board") of Altia Plc ("Altia") on 22 January 2018 and will enter into force on the date of the application for the listing of the Company’s shares on Nasdaq Helsinki Ltd.
The shares of Altia group’s parent company Altia Plc are listed on Nasdaq Helsinki Oy ("Nasdaq Helsinki"). In its communication and disclosure, Altia complies with EU and Finnish legislation, the rules and guidelines of Nasdaq Helsinki, the regulations and guidelines of the European Securities Markets Authority ("ESMA") and the Finnish Financial Supervisory Authority as well as the company’s internal policies and guidelines.
This Disclosure Policy describes the key principles that Altia, as a listed company, complies with in its investor communication and financial reporting and when communicating with its shareholders and other capital market parties, media and other stakeholders.
This Disclosure Policy has been adopted by the Board of Directors of Altia and it is updated if deemed necessary.
Altia’s key principles of communication and disclosure are timeliness, consistency, impartiality, transparency and responsibility. The aim is to guarantee that all market parties have simultaneously and as soon as possible sufficient and correct information of the company, its operations, objectives, strategy and financial situation.
The company reports its financial information and key figures on a group level and for the reportable business segments. Altia publishes regularly information on operating income, balance sheet and financial position, future outlook and other similar matters and their development primarily in its financial statements release, half-yearly report (H1) and interim reports (Q1 and Q3). In addition, Altia publishes annual review, which includes financial statements, Board of Director’s report and auditor’s report and also Corporate Governance Statement and Remuneration Statement.
Altia publishes the financial reports according to a previously announced schedule. The publishing dates for the next financial year are published prior to the start of each financial year.
Altia publishes an assessment of the company’s future outlook and, if so decided by the Board of Directors, a possible earnings guidance in the financial statements release, Board of Directors’ report, half-yearly report and interim reports.. Altia also publishes the Board of Directors’ report, half-yearly report and interim reports. Altia presents an assessment of the key factors and risks affecting the company’s future outlook in the financial statements release, half-yearly report and interim reports.
Altia continuously monitors the Group’s financial result, position and future outlook. A profit warning is disclosed when the company reasonably expects that the future outlook has declined or improved compared to the previously released guidance and such deviation is likely to have a significant effect on the price of Altia’s financial instruments.
Releases published by Altia
Stock exchange releases
A stock exchange release is published to disclose information on facts, matters and circumstances that Altia believes are likely to have a significant effect on the price of Altia’s shares and other financial instruments. A stock exchange release is also used to publish regulated information that is required to be disclosed by means of a stock exchange release (such as manager’s transactions, notices to general meetings and resolutions of the same), even if such releases do not normally include price-sensitive information.
In general, the following events, if significant to Altia, are regarded by Altia as price-sensitive information:
- Changes in Altia’s financial result and position;
- Strategy and changes therein;
- Mergers, de-mergers and other transactions involving Altia as well as other contractual arrangements;
- Reorientation of Altia’s business operations;
- Restructuring schemes, profit improvement programs;
- Litigations and regulatory proceedings and decisions or judgements given therein; and
- Issues of shares or other financial instruments of Altia, public tender offers, share splits or other changes in the number shares.
Issuing a stock exchange release generally follows the review and determination of an obligation of disclosure. This review is conducted simultaneously with the process of assessing the prerequisites to delay disclosure, if relevant.
In addition to the aforesaid, matters to be disclosed as a stock exchange release are defined in the rules of Nasdaq Helsinki Oy. When evaluating the need to publish a stock exchange release attention is paid to whether similar matters have previously been disclosed as a stock exchange release or whether similar knowledge has previously had significant effect on the price of a financial instrument.
In addition, the company publishes press releases on events related to the business of the company that do not meet the requirements set for a stock exchange release but are nonetheless regarded as being newsworthy or of general interest to media and the company’s stakeholders. Further, the company publishes press releases on regional news.
Altia publishes through press releases, amongst other things, invitations to publication of the results and capital market days.
Altia applies a silent period of 30 days before the publication of financial statements, half-yearly reports and interim reports. During this time the representatives of the company do not meet with the capital market representatives or give interviews or comment on the financial standing of the group or
the company’s or market’s future outlook. The dates of the publication of the results and silent periods are disclosed on the investor calendar on the company’s website.
If during silent period an event requires immediate disclosure, Altia publishes the information without delay according to regulations regarding duty of disclosure and decides based on the case whether to give interviews, such communication will be limited to the relevant event only.
Investor, analyst and media relations and spokespersons
Altia aims to actively meet with capital market and media representatives, and answer enquiries from investors, analysts and media without delay.
The company’s CEO and CFO comment on the financial situation and future outlook of the company. Members of the Executive Management Team and experts may give statements regarding their business areas in accordance with the given instructions.
The company’s CEO is responsible for investor relations. Altia’s investor relations function prepares and coordinates all events and presentations directed to shareholders, investors and analysts and is responsible for the preparation of financial reports and stock exchange releases. Investor relations function manages enquiries from shareholders, investors and analysts and comments on the operations and development of the company if needed.
Altia meets regularly with investors and analysts in roadshows, one-on-one meetings, capital market events and seminars. The CEO, CFO, Investor Relations Manager and Corporate Relations and Communications Director participate primarily in the meetings. Also other representatives of Altia may participate in the investor meeting together with the aforementioned persons. All statements in the name of the company are given within the framework of previously published information and precisely according to them.
Corporate Relations and Communications Director is responsible for the group’s media relations and for the preparation of information to be published and for the adherence of coherent communications policy. Group communications unit coordinates, publishes and distributes press releases. Group communications unit and business areas coordinate and process all enquiries from the media, and give statements.
Altia has a crisis communication instructions for the company’s management, employees and other stakeholders in case of a crisis.
The company’s CEO and/or Communication Director is responsible for the management of crisis communication. Depending on the situation, communication can be centralised to a named person. The validity and quality of the information to be published, honesty and quickness are emphasised in crisis communication.
Rumours, market speculations and information leaks
As a general policy, Altia does not comment on possible market rumours, the actions of competitors or customers, the development or the share price or the forecasts of analysts unless it is necessary to correct materially incorrect information that is likely to have a significant effect on the price of the company's financial instruments
In the event that a rumour concerns inside information the publication of which has been delayed and if the information is so precise that it cannot be guaranteed to remain confidential anymore, the company discloses the matter as a stock exchange release as soon as possible.
Information distribution channels and languages
The primary and the most important communication channel for up-to-date information for all stakeholders is Altia’s website (www.altiagroup.com). Altia aims to provide on its website reliable and extensive information to enable investors to form an accurate understanding of the company. The company publishes also materials used in investor and analyst meetings on its website. Some of the material used in investor and analyst meetings may be available only in English.
Altia’s stock exchange releases are published through Nasdaq Helsinki, to key media and on the company’s website where they will be made available in connection with the publication or other disclosure. The press releases are published to key media and on the company’s website. The releases are archived for five years and financial and other reports under regular disclosure obligation for ten years.
Subscriptions for the Altia’s releases can be made on the company’s website.
Altia utilises social media in its communication and the company’s representation in social media is determined by an internal social media guidelines. Social media is not the primary communication channel when publishing information that is under disclosure obligation.
Altia’s official reporting language is Finnish. The releases, which are published under the disclosure obligation are published in Finnish and in English and in other languages when needed.
Altia’s insider policy and insider administration is based on the Market Abuse Regulation and other related regulation, the regulations and guidelines of the Finnish Financial Supervisory Authority, the rules and guidelines for insiders of Nasdaq Helsinki. Further, insider policy, which concerns the use of insider information and principles related to the delay of disclosure and is adopted by the Board of Directors is applied in Altia.
Within the framework of applicable laws and regulations, the company has the right to, in particular circumstances, for compelling reasons, deviate from this Disclosure Policy in which case the company’s CEO shall decide on the deviation.