This disclosure policy has been adopted by the Board of Directors (the "Board") of Viking Line Abp ("Viking Line" or the "Company") to apply as of 3 July 2016. It describes the general principles that Viking Line adheres to in its communication with capital market participants. In addition, it defines the responsibilities relating to communications and investor relations.
As a public limited liability company listed on the main list of NASDAQ Helsinki Ltd (the "Helsinki Stock Exchange"), Viking Line is bound to comply with the applicable disclosure requirements of the EU Market Abuse Regulation (596/2014) and the Finnish Securities Markets Act (746/2012) and other applicable domestic and EU legislation as well as rules and guidelines of the Finnish Financial Supervisory Authority and the rules of the Helsinki Stock Exchange.
According to applicable regulation, a company must as soon as possible announce any unpublished information of a precise nature related to the Company or its listed financial instruments which would be likely to have a significant effect on the price of those financial instruments or related derivatives.
2 Objectives and Principles
The objective of the communications of Viking Line is to provide the market with correct, consistent, relevant and reliable information on the Company to ensure that capital market participants have as transparent and clear a picture of the Company as possible on the basis of which they can reasonably assess the value of the Company's securities.
Stock exchange releases are published to provide information on facts, matters and circumstances that are likely to have a significant effect on the price of the Company's financial instruments. Publication of information shall take place as soon as possible when circumstances have arisen, whereby there is information of a precise nature, which has not yet been made public, relating, directly or indirectly, to Viking Line or its financial instruments, and which, if it were to be made public, would be likely to have a significant effect on the prices of those financial instruments or on the price of related derivative financial instruments (i.e. inside information). The Company may decide to delay the publication of insider information, where the immediate disclosure is likely to prejudice the legitimate interests of the Company and certain other conditions are met (see the Company's Insider Guidelines).
In its communication with capital market participants, the Company adheres to the principle of equal and simultaneous access to information and publishes its financial reports and releases in compliance with the rules and guidelines of applicable regulations.
All published financial reports, prospectuses, articles of association, details of the current Board of Directors and senior management as well as other information provided for distribution is kept readily available on the Company's corporate website www.vikingline.com.
3.1 Responsible persons
The CEO is the designated authorized person to make public statements on behalf of Viking Line. The CEO may delegate this authority to other members of the management team or to other nominated person, if deemed necessary.
The CEO is responsible for the Company's communication and signs all the releases.
The materials of the scheduled releases (interim reports, financial statements releases and annual financial statements) are prepared by the Group Treasurer together with the Finance Information Group (see Insider Guidelines), signed by the CEO or CFO and authorized for approval by the Board of Directors.
The CEO and CFO are responsible for investor relations relating to the Company's financial results.
The Group Treasurer is responsible for the distribution of releases according to the instructions by the CFO and the CEO and he/she reports to the CEO.
3.2 Communication Channels
Information to be disclosed shall be disclosed to the market in a manner that ensures fast public access to such information on a non-discriminatory basis. This is accomplished by distribution of stock exchange releases through a newswire distribution network in accordance with the rules of Helsinki Stock Exchange.
Published information will simultaneously with the disclosure to the market be provided to the Helsinki Stock Exchange, in the manner prescribed by the Helsinki Stock Exchange, and will made available on the Company's website as soon as possible.
Matters pertaining to the Company's ordinary business operations which are not deemed to have a significant effect on the price of the Company's financial instruments, but which nevertheless are intended to be made public, are generally announced by press releases and not by a formal stock exchange release.
Up-to-date information on Viking Line is available on the Company's website. All financial reports and stock exchange releases must be published without undue delay on the corporate website, on which all other information for investors is also published. All information published will be available on the corporate website for at least five (5) years after their publication.
The Company's official reporting language is Swedish. However, the Company prepares and discloses stock exchange releases also in the Finnish and English languages.
3.3 Forecasts and forward-looking statements
Forward-looking statements shall always be presented in the yearly report by the Board of Directors, in the financial statement release and in the interim reports under a separate heading and shall, to the extent possible, be made in an unambiguous and consistent manner.
Where the Company reasonably expects that its development will deviate significantly from a forward-looking statement previously made by the Company or from what can be justifiably concluded based on previously published information and such deviation is likely to have a significant effect on the price of the Company's financial instruments, the Company shall disclose information about the deviation. Such disclosure shall also reiterate the previous forward-looking statement.
3.4 Rumours, Market Speculation and Information Leaks
As a general policy, the Company does not comment on market rumours, speculation by the media, share price performance, actions of competitors or customers or analyst estimates unless the Company deems it necessary to correct clearly incorrect specific information that is likely to have a significant effect on the price of its financial instruments. Neither will the Company comment on unpublished and unfinished business transactions, as long as the conditions for delaying disclosure are fulfilled (See Insider Guidelines).
If the Company learns that information that is likely to have a significant effect on the price of the Company's financial instruments has leaked prior to a disclosure, or has been inadvertently disclosed to a third party not bounds by confidentiality obligations, the Company shall publish a stock exchange release on the matter as soon as possible.
Information leaks are prevented by maintaining insider registers, as necessary, by having non-disclosure undertakings in place, and by instructing and training personnel on insider issues. The Company has adopted insider guidelines which apply to all its employees, the Board of Directors, the CEO and other management.
3.5 Contacts with media and analyst
Press and analyst briefings in conjunction with financial reports
In conjunction with the issuing of financial reports, the Company may invite analysts and the media to a closer presentation of the Company and the Company's financial position. No new or share price sensitive information may be disclosed at these briefings. The presentation may also be broadcasted via web streaming. Possibility to participate in the presentation by conference call may also be provided. Material used at the presentation is published on the Company's website.
Other media meetings
The Company meets regularly with representatives of business press and other media. If it is deemed appropriate or desirable, press conferences may be arranged. Such a press conference is also open to analysts and investors; however, press conferences should be used with restriction. The Communication Manager is responsible for arranging press conferences after consultation with the CEO.
The Company also meets with media on a one-on-one basis. One-on-one meetings with the media can be carried out individually by the identified spokespeople, provided that no confidential, new or share price sensitive information is communicated and that the interview does not relate to corporate strategic issues. The CEO should to the extent possible, attend interviews that focus on corporate strategic issues.
3.6 Crisis Communication
A crisis is a situation in which the Company's normal operations are endangered typically for unexpected reasons. Once the event or development leading to a crisis has occurred, internal and external communication is often crucial for the Company.
Risks connected to the Company's operations that may develop into a crisis are systematically evaluated in an annual risk mapping by the Company's management. The Company's risk management requires sufficient preparedness from all group functions in order to manage an exceptional situation.
The Company has adopted a crisis communication plan for handling crisis situations whereby the CEO is responsible for external communications, and is supported by the CFO, the head of communications and the relevant executive with information about the relevant circumstances.
4 Silent Period
Viking Line does not arrange or participate in any one-on-one meetings with the media, analysts or investors during the period from the end of the quarter to the date of publication of a financial report and at least 30 days prior to the publication of the financial report. One exception to the rule is the publishing of stock exchange releases regarding business events, in which case representatives from Viking Line must be able to answer questions; however, in such communication, any comments about the upcoming financial report should be avoided.
5 Insider Register
Viking Line maintains permanent and project-specific insider registers in accordance with applicable regulation. More detailed rules in this respect are set out in Viking Line's insider guidelines.