Heimstaden Bostad AB actively assesses and monitors investment- and equity capital transactions as well as financing opportunities throughout Europe, all of which may involve insider information.
To ensure responsible management of this information and prevent any potential insider trading or tipping, the CEO has instructed the Chief Legal Officer (CLO) to develop, maintain, and implement an Insider Policy and a comprehensive Insider Manual for the company in accordance with the Board's instructions.
The Policy serves the following purpose:
- Uphold a strong ethical standard and foster trust from the public and capital market. It prohibits representatives from engaging in personal transactions involving financial instruments or other business activities that could create conflicts of interest with the Company, its investors, or potential group companies.
- Ensures compliance with laws, rules, and regulations, including those applicable to Swedish public companies with instruments listed on regulated markets like Oslo Børs and Euronext Dublin.
- Clearly outlines the primary responsibilities of the Company's directors, officers, employees, and the Manager (Representatives). It covers responsibilities related to inside information, insider trading, trading restrictions, and disclosure requirements.
- The Company has established an Insider Committee, chaired by the CLO, comprising the CEO, CFO, CIO, and CCO. Written submissions regarding potential insider matters are reviewed and classified by the Committee according to applicable Laws and Regulations.
Core Principles
Our Code of Conduct and Insider framework sets forth core principles that all Company Representatives must abide by:
- Representatives are prohibited from trading in our listed financial instruments.
- Representatives possessing inside information related to the Company or potential target companies are prohibited from trading in the relevant financial instruments.
- Representatives in possession of inside information are prohibited from disclosing it.
- If inside information is leaked, the Company will promptly make it public through a press release and notify the exchange.
- The Core Principles apply for 3 months after a Representative's employment or office with the Company ends, in accordance with Laws and Regulations.
These principles also extend to individuals/entities closely associated with the Representatives, as specified in the Insider Manual. However, indirect transactions with no influence or control are excluded from the Core Principles.