Electronic notification page one (Basic information)

• On the front page of e-services, under services, select the title “Managers’ transactions”.
• Select “Form” as the notification method if you want to fill in the notification on the pages or “XML file” if you want to attach a file that you have already filled out to the notification.
• A new notification shall always be selected for the notification, unless the intention is to correct a previously submitted notification.
  • If “Amendment” is selected, the case number of the notification to be corrected and the reason for the amendment will open on the form to be completed. See below for more detailed instructions on how to amend a transaction notification.

• If you fill in the notification on your own behalf, select “Own Notification”. Your information will be automatically completed in the notification. Select “Natural Person” as the person obliged to report transactions.
  • If you are making a notification on behalf of another person or entity you represent, select “Notification on behalf of another person” and, correspondingly, choose “Natural Person” for the person and “Legal person” for the entity you represent. Complete the name and position of the obliged person or the name of the entity.
  • If the party obliged to notify the transaction is a person closely associated to a Raisio plc’s manager, fill in the name and position of the manager in question.

• Complete the issuer’s name (Raisio Plc) and LEI (74370083282NHIP4QD02).

Electronic notification page two (Information about the transaction)

• Complete the transaction date and select the trading venue/market place from the drop-down menu.
• Select the nature of the transaction from the drop-down menu.
• When the notification concerns a transaction with a share in Raisio Plc, select “Share” from the drop-down menu and enter the ISIN code (for the free share: FI0009002943 and for the restricted share: FI0009800395)
• Provide details of transactions
  • First, select the price unit to enter the volume and unit price.
  • If there are several executed items, you can also copy and attach separate transaction rows into the field reserved for them.
  • Note: if you want to report different types of transactions or transactions in different marketplaces/trading venues in the same report, add a separate page for each one.
  • The form automatically calculates the combined data.

Electronic notification page three (Summary)

• Copy the corresponding plain text from the page, or save the notification in PDF format from the next fourth page. Send the notification by e-mail to Raisio plc at johdonliiketoimet@raisio.com. Include your phone number in the e-mail so that you may be reached, in case there are any questions related to your notification.

Electronic notification page four (Submission)

• Click the “Send” button to send the notification to the Financial Supervisory Authority.
• At this stage, you can still download the notification in PDF format and send it as an attachment by e-mail to Raisio plc.

The electronic transaction notification can be amended by submitting an amendment notification

• In the e-service top menu, select the “Case folder” and the notification you want to correct from the submitted matters.
• Copy the case number of the report to be corrected (which is in the format FISA XXX/02.05.10/2021).
• Click the “Copy for template” button.
• On the first page of the form, change the notification type to “Change”. In this case, two additional fields will open on the form, to which the document number of the notification to be changed and the reason for the change will be filled in.
• After filling in the additional fields, you can make the amendments you want to the items that you want to correct in the form.
• Copy the text from the page or save the notification in PDF format and send it by e-mail to Raisio plc at johdonliiketoimet@raisio.com so that the company can publish it as a stock exchange release.
• Finally, send the amended notification to the Financial Supervisory Authority in the same way as the first notification.

Name of the register:

Raisio plc’s Insider Management Register

Controller and contact information:

Raisio plc (Business ID 0664032-4)
Address: Raisio plc, P.O. Box 101 (Raisionkaari 55),
FI-21201 Raisio, Finland
Telephone: +358 2 443 2111
Email: privacy(at)raisio.com

Purpose and legal basis for processing personal data

The processing of personal data is based on Raisio plc’s statutory function or obligation.

As required by the Market Abuse Regulation (MAR, EU No 596/2014), Raisio plc shall maintain a list

• of Raisio plc’s managers and their closely associated persons referred to in MAR and of their transactions with Raisio plc’s financial instruments
• of persons who, based on their position, employment or service contract or on other grounds, have a project-specific access to the Raisio Group’s inside information

These registers are maintained in Euroclear Finland Ltd’s system.

Raisio plc does not maintain a permanent list of insiders. Raisio plc does maintain a list of persons who, on the basis of their position or rights, have regular access to the Raisio Group’s undisclosed financial information and who are therefore prohibited from trading with Raisio plc’s financial instruments during the closed window periods.

Raisio plc also maintains a whistleblowing channel under the Finnish Securities Market Act Chapter 12 Section 3. The channel is provided by WhistleB and there is a separate privacy policy available here www.raisio.com/en/privacy-statement-for-the-whistleblowing-channel/

Data subject groups and categories of personal data

The following information on Raisio plc’s managers, their closely associated persons and their transactions are recorded in the list:

• first name and surname (also surname at birth)
• personal ID /date of birth
• nationality
• home address and personal phone numbers
• basis for the entry; date and time for both beginning and ending of the entry
• transaction notifications submitted to Raisio plc

The following information on persons with access to the company’s inside information is stored in the insider lists for projects:

• first name and surname (also surname at birth)
• personal ID /date of birth; nationality
• home address, e-mail address and personal phone numbers
• name and address of the workplace, work phone numbers
• person’s duties and the basis for entering him/her in the list
• date and time of the beginning and ending of the entry in the insider list

The list of persons with access to the Raisio Group’s unpublished financial information includes the following personal information of the persons in question:

• first name and surname
• position
• employer, contact details (unless Raisio plc)
• email address and phone number

Sources of data

Personal data is collected from the data subjects, book-entry system, Financial Supervisory Authority or from other public databases, such as the Trade Register.

Transfer or disclosure of information 

The controller is obliged by law to disclose information to competent authorities, such as Financial Supervisory Authority, ESMA or the police, to publish the transaction notifications submitted and to keep the information regarding the transactions on the company’s website and to deliver it to the Nasdaq Helsinki Oy’s Central Storage Facility.

The information is not transferred or disclosed outside the EU or European Economic Area (EEA). If the transfer or disclosure is necessary for the purpose of processing the personal data or for the technical implementation of data processing, it is carried out in accordance with the requirements of the personal data legislation.

Retention periods

Data retention period of personal data is determined in accordance with the requirements of MAR and other applicable company and securities market legislation. Retention period is in principle 5 years from the registration of the personal data or from their last update.

Information about the persons on the list of managers and their closely associated persons is held by Euroclear Finland Oy for 11 years. The information about those persons who have not been required to report by any organization in the insider register service for more than 11 years will be centrally removed from the service. The same applies to those persons who have not been related to or connected to any reporting party for more than 11 years. The retention period is based on the Financial Supervisory Authority’s right to impose a penalty fee for a violation or neglect of the reporting obligation in question.

The management transaction notifications are kept on the company’s website for the minimum of five years.

The information in the list of persons subject to trading prohibitions is maintained for as long as the person in question is on the list.

Principles of data protection

Only the employees with the right to process the data are entitled to use the system. Access rights to the electronic system are recorded in the list and loggings onto the system are monitored using log data.

The data in electronic form is protected by user IDs, passwords, firewalls and other technical means. Manual material is kept in a space accessible only to those who need the information to perform their duties.

Data subject’s rights

The data subject has the right to know what data of him/her has been stored in the register and to have a copy of his/her personal data to be processed unless this has an adverse effect on the rights of others.

The data subject has the right to the rectification of inaccurate or insufficient data.

The data subject has the right to request for a removal of his/her personal data from the register unless the data processing is based on the fulfilment of the controller’s statutory obligation.

The data subject is not entitled to request restriction of the processing of his/her personal data or its transfer to another controller since the data processing is based on the fulfilment of the controller’s statutory obligation.

The personal data is not processed for the purposes of direct marketing.

All requests concerning the verification etc. shall be made in writing to the Data Controller.  The data subject must prove his/her identity in an acceptable way. The controller will reply in writing within the legal time frame (as a rule, within 30 days), even if the data subject’s claim is not accepted.

The data subject has the right to file a complaint with the supervisory authority if the data subject considers that his/her information has not been processed in accordance with this Privacy Policy or legislation. The supervisory authority’s contact information: Data Protection Supervisor’s Office, P.O. Box 800, 00521 Helsinki; tel: +358 29 56 66700; tietosuoja(at)om.fi.

Changes

Raisio plc reserves the right to change this Privacy Policy on the basis of its business development or a change in the legislation.

Updated 1 February 2024