Disclosure obligation 

The Securities Markets Act (SMA) obliges issuers of securities admitted to public trading to publish all its decisions and all information on the issuer and its activities materially affecting the value of the company's securities. The information must be disclosed without undue delay.

The purpose of the disclosure obligation is to ensure the possibility of equal, equitable and simultaneous access to information by the investors. The information must therefore be reliable, comprehensive, timely and comparable. The objective is that the investors have access to essential and adequate information for an informed assessment of the issuers and their securities.

In connection with the listing, the issuer's disclosure obligation includes the relevant prospectus and the subsequent disclosure of periodic and ongoing information. In addition, the company must publish an annual summary of information it has published during the preceding financial period according to the relevant securities market provisions.

Dissemination and storage of information

According to the Transparency Directive issuers must disseminate regulated information in a manner ensuring efficient and fast access on a non-discriminatory basis. In the Directive, a distinction is made between disclosure and dissemination and storage of information.

As regards the dissemination of information, the Transparency Directive emphasises listed companies' obligation to disseminate the information to the media so as to ensure as extensive a dissemination of information as possible in the home country and also in Europe where feasible. The requirement of Europe-wide dissemination may be considered fulfilled by, for example, submitting the information to international news agencies specialised in the communicating of financial information. Listed companies may disseminate their information themselves or purchase the service from specialised service providers. However, the responsibility for the dissemination of the information always lies with the listed companies.

The regulated information must be disseminated to the media as an unedited full text. As regards the publication of interim reports, interim management statements and financial statement releases, it is sufficient that the media is provided with such information disclosed in these statements within the scope of the periodic disclosure obligation that is likely to have a material effect on the value of the security, and that the media is informed that such a statement has been published. In addition, the release shall state where investors may access the statement. However, the release submitted to the organiser of public trading and to the release storage (OAM) must also include the complete interim report, interim management statement and financial statement release as an annex. As regards financial statements and management reports, it is sufficient that the media be informed that these have been published, together with information on where investors may access this information.

The information to be published must be disseminated not only to the media but also to the organiser of public trading (NASDAQ OMX Helsinki Oy) and to the Financial Supervision Authority (FIN-FSA). FIN-FSA considers that the legal obligation of submitting information to FIN-FSA is fulfilled when a listed company submits the information to the officially appointed mechanism for storing regulated information (NASDQA OMX Helsinki Oy), where FIN-FSA can access it. Thus no separate submission of information to FIN-FSA is required.

See more on dissemination of interim reports, interim management statements and financial statement releases on Markkinat 5/2010 (in Finnish).

Storage of information

As regards published information, the objective laid down in the Transparency Directive is to build a Europe-wide officially appointed mechanism (OAM) for storing regulated information as a service to the investors. In Finland, NASDAQ OMX Helsinki Oy serves as an OAM, as referred to in the Directive. In the OAM, the information is kept available for the public for at least five years. The intention is that OAMs of different countries will later be interconnected in a mutual network for serving investors throughout Europe.

Listed companies must retain financial reports disclosed within the scope of periodic disclosure obligation on their websites for at least five years. It is also recommended that the issuer keep other information published under the disclosure oblication on its internet site available to the public for at least five years.

9 May 2011