Disclosure policy
As a listed company in the London AIM and Helsinki Nasdaq First North marketplaces Faron Pharmaceuticals complies with the EU Market Abuse Regulation, the UK Market Abuse Regulation, the AIM Rules for Companies, the Finnish law (Market Abuse Regulation, MAR) and the Nasdaq First North Growth Market Rulebook (First North Rules).
The objective of Faron Pharmaceuticals Ltd’s communications is to provide fair disclosure of information to the public in a consistent manner. The information made public by the Company shall be accurate, complete and based on verifiable facts. The information shall also give a true and fair picture of the Company’s operations and be released without delay. Faron’s Disclosure policy describes the key principles and procedures that the Company complies when disclosing information to the markets and when communicating with capital market representatives.
As a general policy, the Company does not comment on market rumours, stock price trends, actions of competitors or customers, analyst estimates, or confidential and unfinished business unless the Company deems it necessary to rectify clearly incorrect specificinformation. In the event that confidential information leaks to the public domain, the Company shall issue an announcement.
The Funding & IR department, in close co-operation with the Company’s spokespersons, nominated adviser and certified adviser, will see to it that information is notified if and when required. Regulatory announcements are published in English.
The release types that Faron publishes are company announcements and press releases. The primary channel for investor communications is the company’s website.
The Board of Directors has overall responsibility for disclosing information to the market. Day-to-day responsibility for operating this policy and ensuring its maintenance and review has been delegated to the CEO, who is the designated authorised person to make public statements on behalf of Faron. The CEO may delegate this authority to other members of the management team. In addition to the CEO, the CFO is able to communicate externally on behalf of the Company and authorised to comment on financial matters.
The CEO, or his designee, is responsible for the Company’s communications and signs off all announcements. Half-yearly reports and annual accounts are prepared by the CFO, signed off by the CEO and authorised for approval by the Board of Directors.
Disclosure of inside information
AIM rules
Under AIM Rule 11, the company must issue an announcement without delay of any new developments which are not public knowledge which, if made public, would be likely to lead to a significant movement in the price of its shares. By way of example, this may include matters concerning a change in its financial condition, its sphere of activity, the performance of its business or its expectation of its performance.
MAR
Under Article 17(1) of MAR, the company must, subject to some limited exceptions, inform the public as soon as possible of inside information which directly concerns the company. Inside information is defined as information of a precise nature that has not been made public, relates directly or indirectly to the company or its shares and, if made public, would be likely to have a significant effect on the price of those shares.
First North rules
Under the First North Rules, the company must disclose inside information in accordance with Article 17 of MAR. Set out in section 4.1 of the First North Rules is guidance on certain circumstances and events that in the view of the operator of the Nasdaq First North Growth Market may involve inside information under MAR.
Delay of disclosure
AIM rules
Unless disclosure of the inside information is required under MAR, the company may delay disclosure of price-sensitive information under the AIM Rules if it is an impending development or matter in the course of negotiation provided such information is kept confidential.
MAR
Under Article 17(4) of MAR, the company may delay disclosure of inside information where immediate disclosure is likely to prejudice the legitimate interests of the company, the delay is not likely to mislead the public and the company is able to ensure the confidentiality of the information.
First North rules
Under section 4.8(f) of the First North Rules, the company will notify the certified adviser if it decides to delay disclosure of inside information.
Spokespersons
Faron’s Board of Directors has overall responsibility for disclosing information to the market. Day-to-day responsibility for operating this policy and ensuring its maintenance and review has been delegated to the CEO, who is the designated authorised person to make public statements on behalf of Faron. The CEO may delegate this authority to other members of the management team.
In addition to the CEO, the CFO is able to communicate externally on behalf of the company and authorised to comment on financial matters.