Insiders and insider policy

The Sectra Board of Directors has adopted a company insider policy to reduce the risks of unlawful disclosure of inside information, insider dealing and other unlawful behavior and to facilitate Sectra’s compliance with applicable insider rules. The policy covers all Sectra employees (Covered persons), both permanent and temporary positions.

All employees in Sectra, not only Persons Discharging Managerial Responsibilities, are covered by the rules on prohibitions on trading in Sectra shares or debt instruments during certain periods (referred to as ‛closed periods’). This means that it is not permissible to act in Sectra shares 30 calendar days prior to the publication of an interim report or year-end report. This prohibition apply to the Covered persons, irrespective of actual knowledge regarding inside information.

Sectra’s insider policy entails the following provisions

• Prohibitions on unlawful/unauthorised disclosure of inside information.
• Obligations for Covered Persons to immediately report existence of any and all potential inside information to the Chief Investor Relations Officer.
• Prohibitions on using knowledge of inside information for oneself, or on behalf of another party, to buy or sell shares or debt instruments that have been issued by Sectra.
• Prohibitions on trading during certain periods (referred to as ‛closed periods’) in shares or debt instruments that have been issued by Sectra. This prohibition apply to the Covered Persons, irrespective of actual knowledge regarding inside information.
• The Covered Persons and other persons who, as a result of their assignments, gain access to inside information shall be entered into an insider list (Log) and receive written notice thereof. To ensure the confidentiality of the inside information if Sectra decides to delay public disclosure, Sectra shall maintain such insider list (Log) until the inside information is publicly disclosed.

In addition, for persons discharging managerial responsibilities (PDMRs) in the Sectra Group, the policy also entails:

• PDMRs must obtain the go-ahead from Sectra’s Chief Investor Relations Officer before transactions are carried out. The CEO must obtain go-ahead from the Chairman of the Board before transactions are carried out.
• Reporting obligations to the Swedish Financial Supervisory Authority (Sw. Finansinspektionen) and to Sectra with respect to transactions performed by PDMRs and persons closely associated with them.
• PDMRs and persons closely associated with them will be entered to the list Sectra shall maintain.

List of Persons Discharging Managerial Responsibilities in Sectra

Sectra has established a list of PDMRs in the Group. The list includes:

• Board of Directors
• The CEO and President 
• Executive Vice Presidents
• Other selected Executive Managers