Principles on Related Party Transactions
Elisa complies with legislation concerning related party transactions.
In accordance with the legislation and the Corporate Governance Code,
Elisa ensures that requirements related to monitoring, assessing,
decision-making and disclosure of related party transactions are
complied with. The Board of Directors has adopted a Related Party
Transaction policy which contains principles for monitoring and
assessing Elisa's related party transactions. The Board of Directors
monitors and assesses related party transactions at Elisa.
Elisa has defined the parties that are related to the company and
Elisa's Legal Affairs department maintains a list of individuals and
legal persons who are considered as related parties. Elisa maintains
up-to-date guidelines on related party regulation and the monitoring
thereof. Requirements regarding related party transactions have also
been taken into account in Elisa's Anti-Corruption and Bribery Policy
and Elisa's Conflicts of Interest Policy.
Elisa may enter into transactions with its related parties, as long
as the transactions are part of Elisa's ordinary business operations and
made according to ordinary business terms and conditions. In such
situations Elisa's internal guidelines and decision-making processes
must be complied with. Related party transactions that deviate from
normal business operations, or are not made according to ordinary
business terms, are decided on by the Board of Directors, respecting
provisions on disqualification.
Potential related party transactions are regularly monitored in
Elisa's business and support units and through surveys conducted to the
related parties. A director, who belongs to the related parties of
Elisa must, without undue delay, notify Elisa's Related Party
Administration about a related party transaction or a planned related
party transaction that the director has become aware of. The Internal
Auditing function monitors any potential conflicts of interest. Results
of the monitoring of related party transactions are reported regularly
to the Audit Committee.
Elisa reports on related party transactions regularly in its
financial statements. Related party transactions that are material to
shareholders and that deviate from normal business operations or are not
made according to ordinary business terms and conditions, shall be
published in accordance with the Securities Market Act and the Nasdaq
Helsinki rules of the Exchange.
Main procedures relating to insider administration
Elisa complies with the guidelines from Nasdaq Helsinki Ltd for
insiders in force at any given time. In addition, Elisa’s Board of
Directors has approved insider guidelines for Elisa Group to complement
Nasdaq Helsinki’s guidelines for insiders.
According to the Market Abuse Regulation (Regulation (EU) No
596/2014), the members of Elisa's Board of Directors and Elisa's
Corporate Executive Board are defined as persons discharging managerial
responsibilities within Elisa. A person discharging managerial
responsibilities within Elisa must not conduct any transactions relating
to Elisa's shares or other financial instruments during a closed period
of 30 calendar days before the announcement of an interim financial
report or a year-end report. It is advisable for a person discharging
managerial responsibilities to make long-term investments in Elisa and
to conduct the transactions after the publication of Elisa’s financial
results. Transactions made by persons discharging managerial
responsibilities in Elisa and persons closely associated with them are
disclosed according to the Market Abuse Regulation.
Insider lists include persons who have access to specific inside
information (insider projects). A person listed on the insider lists
must not make any transactions in Elisa shares or other financial
instruments during the time they are registered on the list.
Elisa’s Legal Affairs department monitors compliance with insider
guidelines and maintains the list of persons discharging managerial
responsibilities and persons closely associated with them as well as the