Disclosure Policy

PHM Group Holding complies with the Rules to Issuers of Shares and insider guidelines issued by Nasdaq Helsinki Ltd, the Companies Act (624/2006, as amended), the Securities Markets Act (746/2012, as amended) and other applicable laws and legislation, the EU Market Abuse Regulation ((EU) 596/2014 as amended, “MAR”), and with the lower-lever regulation issued pursuant thereto as well as with the guidelines of the European Securities and Markets Authority (ESMA) and the Finnish Financial Supervisory Authority (FIN-FSA).

The company’s communications objectives are to ensure that all market participants have simultaneously and without delay access to equal, sufficient, and substantial information on the material factors relating to the company and its business, where these factors may influence the value of the company’s financial instruments. The company communicates consistently to all its interest groups regardless of whether the information is positive or negative for the company. The key disclosure principles are consistency, clarity and providing reliable and timely information.

Disclosed information and disclosure times

PHM Group Holding publishes information of its financial position, results, and the development of those in financial statements, annual reports, half year reports and interim reports. The company publishes its financial statements, annual report, half year report and interim report without undue delay after the information being published is confirmed and after the Board of Directors or other competent organ has made the decision on publishing.

The company publicly discloses the insider information as soon as possible, unless the disclosure is delayed in accordance with the MAR, whereupon the conditions of delay of disclosure under the MAR need to be met. The company has an insider policy that contains more detailed instructions for evaluating and disclosing inside information, as well as for evaluating and monitoring the conditions and timing of delay of disclosure.

The company discloses other matters to be disclosed in accordance with the Stock Exchange rules and other rules and legislation applicable to the company.

Language of reporting, distribution, and availability

All company announcements and press releases are published in Finnish and English.

The main source for company information is the company’s website www.phmgroup.com/investors. All company announcements are published simultaneously on company’s website. All company announcements are kept on the company’s website for at least five years and financial reports for ten years.

The company announcements are delivered simultaneously to the Stock Exchange.

Stock exchange release
The Company issues stock exchange releases to disclose inside information and matters covered by the regular disclosure obligation and all other decisions, matters related to the company’s operations and other information that the Company is obliged to disclose pursuant to applicable regulation.

Press release   
The Company issues press releases on matters and events that do not meet the criteria for stock exchange releases but are newsworthy or otherwise in the interest of company’s interest groups.

Closed period

PHM Group Holding observes a 30-day closed period preceding the publication of its financial results, such as half-year financial reports and financial statements. During this time, the members of the Board of Directors and management team, who participate in preparing these financial reports, are prohibited from trading with financial instruments issued by the company.

Silent period

Regularly published financial reports are always preceded by a silent period, which begins 30 days prior to the publication date of the financial report. During the silent period, the company’s representatives refrain from meeting with or contacting investors, analysts or other capital market representatives and will not give inter-views regarding the financial state of the company. However, the company may answer questions concerning any regular business news announced during the period.