The purpose of this disclosure policy is to define the procedures that the company will adhere to in its investor communications and financial reporting when making disclosures or issuing other external communications. Honkarakenne’s disclosure policy seeks to support an accurate formation of the company’s share value by providing capital markets with accurate, sufficient and timely information about Honkarakenne’s operating environment, strategy, objectives, operations and financial position. The policy and its procedures also seek to ensure that the company’s external communications, such as stock exchange releases, comply with security markets legislation and any other applicable regulations. The company’s key communication principles are timeliness, concurrency, continuity, and transparency.
Honkarakenne’s Board of Directors approved this disclosure policy and it will be updated as necessary.
Honkarakenne releases financial information in accordance with a published timetable. Information about Honkarakenne’s financial position, balance sheet, financial standing, outlook, profitability development or any other significant issues relating to the company’s operations and operating environment are primarily disclosed in the half-year review and financial statement release. If significant new information concerning such topics is provided between these reports, it is published as a stock exchange release.
Honkarakenne does not comment on market rumours, share price trends, or analysts’ forecasts. However, Honkarakenne may consider issuing a stock exchange release to correct any rumours or substantially incorrect information that may have a significant impact on the company’s share value.
Honkarakenne meets with capital market and media representatives as necessary, and seeks to respond to queries from investors, analysts and the media without delay. These meetings seek to provide background information about Honkarakenne and its operating environment. Discussions are based on information that has been previously published by the company or is generally available in the market, and should therefore not disclose any new information that may have a significant impact on the company’s share value.
Comments on the company’s financial position, overall market and outlook are made by Honkarakenne’s President & CEO and CFO, or by a person appointed by them. Experts and other members of the Group Management Team may give statements concerning matters within their own areas of responsibility, in accordance with the instructions they have received.
3 Disclosure dates
3.1 Disclosure of periodic information and other regular reporting
Honkarakenne regularly publishes
- a half-year review
- a financial statement release
- full Financial Statements in a previously announced week and at least three weeks before the Annual General Meeting in which they will be approved
- a Report of the Board of Directors in conjunction with the publication of the Financial Statements
- an Auditor’s Report in conjunction with the publication of the Financial Statements
- a Corporate Governance Statement as a separate report on the same day that the Report of the Board of Directors is published
mandatory information without undue delay, once it has been confirmed and verified, and either the Board of Directors or another of the company’s authoritative bodies has approved its publication.
The company also publishes a salary and remuneration report in good time on its website before the Annual General Meeting.
The publication schedule for the following financial year is always announced before the end of the current financial year.
3.2 Silent period
Honkarakenne always observes a silent period before the publication of its regular financial reports. The silent period begins 30 days before the publication date of the next report. During this time, company representatives will not give interviews and will not meet with investors, analysts or other market actors. Interviews concerning insider information published during the silent period will be decided upon on a case-by-case basis.
3.3 Obligation to disclose insider information, delayed disclosure of insider information, and other mandatory disclosures
The company publishes insider information as soon as possible, unless the disclosure of said information has been delayed, in which case the Market Abuse Regulation’s conditions for delayed disclosure must be fulfilled. When a decision is made to delay disclosure, the conditions for delayed disclosure are documented, an insider list is established, and a written decision is drawn up in accordance with Honkarakenne’s official template. When the insider information is published, the company will inform the Finnish Financial Supervision Authority of its decision to delay disclosure.
The company also publishes other mandatory information (such as notifications of General Meetings) in accordance with the rules of the stock exchange.
4 Stock exchange releases
Honkarakenne uses stock exchange releases to publish insider information and any information that falls within the scope of the company’s ongoing disclosure obligation and obligation to disclose periodic information. Stock exchange releases are also used to make other mandatory disclosures required by the rules of the stock exchange or other regulations.
4.1. Disclosure of periodic information
Reports relating to the company’s obligation to disclose periodic information contain key information about the company’s financial standing and result, and trends in these areas. The company reports its financial figures at Group level.
The company gives its annual outlook in the Report of the Board of Directors. The company also forecasts future developments in its half-year review and financial statement release.
4.2 Ongoing disclosure obligation
Insider information that falls within the scope of the company’s ongoing disclosure obligation may include:
- Substantial changes in outlooks
- Positive or negative profit warnings
- Strategy changes
- Significant investments and financing arrangements
- Changes in the constitution of the Board of Directors or Group Management Team, or a change of company auditor
- Significant legal action or other official proceedings, and the decisions made
- Significant mergers, acquisitions and joint ventures
- Exceptionally large or otherwise significant orders and agreements
Honkarakenne has internal guidelines for evaluating the significance and relevance of information. The Chair of the Board of Directors, President & CEO or CFO approves stock exchange releases in accordance with the guidelines.
4.3 Other mandatory disclosures
The company also discloses the following via stock exchange releases:
- Notifications of General Meetings
- Decisions of General Meetings
- Significant share-based incentive schemes
- Flagging notifications
- Management transactions
5 Press releases and investor news
Honkarakenne uses press releases or investor news to publish any news and events relating to Honkarakenne’s business that do not meet the criteria for disclosure of insider information or a stock exchange release yet are still deemed newsworthy or of general interest to stakeholders. Press releases contain information about Honkarakenne’s standard business operations that is deemed to be of general interest to investors and the media. Trade press releases contain more detailed information about Honkarakenne’s collections, products, technology and operating methods. Local releases contain localised information.
News about the following business-related topics are published as press releases and/or investor news:
- standard orders and agreements
- descriptions or customer case studies of successful projects
- new product or collection launches, and new technical breakthroughs
- cooperation agreements with customers and partners
Press releases and investor news are primarily published in Finnish and English, but may also be published in other languages depending on their relevance to local markets.
6 Communications channels, distribution, and availability
The main source of information about the company is its website, www.honka.com. All of the company’s releases are available on the company’s website, where they will be made available when published, or in conjunction with the publication of another item. The website contains at least a five-year archive of stock exchange releases and a ten-year archive of financial and other regular reports (Financial Statements, Reports of the Board of Directors, Corporate Governance Statements, Auditor’s Reports and other financial reports).
The company’s official reporting language is Finnish. Stock exchange releases are published simultaneously in Finnish and English. Press releases are published in Finnish and/or English. The company makes material used in meetings with investors and analysts available on its website.
The company utilises social media in its communications. However, social media is never the primary channel for the publication of new information or any information governed by disclosure obligations. Social media’s role is to support other communication channels.
7 Exceptional circumstances
The company’s guidelines on crisis communications should be followed in exceptional circumstances. Crisis communications seek to support crisis management by providing expertise and tools, and by giving correct information to important sections of the general public.
8 Insider guidelines
In its management of insiders and insider information, Honkarakenne adheres to the Market Abuse Regulation (MAR), Nasdaq Helsinki Oy’s insider guidelines, and Honkarakenne’s insider policy.
Members of Honkarakenne’s Board of Directors and Group Management Team, as well as certain other members of Honkarakenne’s personnel, may not trade in the company’s shares for a period of 30 days before the publication of Honkarakenne’s financial statement release or half-year review. Anyone holding a management position must schedule their transactions in Honkarakenne shares during periods when the market has access to comprehensive information about figures and factors that impact share value.
The company will draw up an insider list for all projects that involve insider information. Insiders are notified in writing of their insider status and provided with instructions of the obligations of insiders.
Honkarakenne’s President & CEO is responsible for supervising and interpreting the company’s disclosure policy When required, the President & CEO and CFO will provide further guidelines on the practical implementation of Honkarakenne’s disclosure policy. If there are pressing grounds to do so, the President & CEO has the right to make individual exceptions to the company’s disclosure policy, within the bounds of legislation and regulations.