QPR Software’s Insider Guidelines include Nasdaq Helsinki Ltd’s Guidelines for Insiders of Listed Companies (January 3, 2018) and the Market Abuse Regulation (MAR). Both documents are part of QPR’s guidelines unchanged. The QPR Insider Guidelines set trade restrictions prohibiting Persons Discharging Managerial Responsibilities (PDMRs), permanent insiders and event-based insiders from making transactions with QPR’s securities during a closed period of 30 days before a financial report is made public. The closed period ends on the day after the publication of a financial report. According to QPR’s Insider Guidelines, permanent insiders must notify the CEO and the Chairman of the Board about the intention to trade QPR’s securities prior to executing a transaction.
The CEO, members of the Board of Directors and the executive management team are considered PDMRs – this is because they are regularly exposed to inside information and have the right to make decisions regarding the future of QPR. QPR’s permanent insiders include employees or other outsourced persons that due to their position or the nature of their responsibilities have access to inside information.
In case QPR prepares an event that could significantly impact the company’s value (e.g. a corporate acquisition), an event-based insider list must be created for the project. Event-based insiders are persons that contractually work for QPR either directly or indirectly and have access to inside information; as well as any organization that is provided inside information on the project.
QPR's CFO manages insider issues and supervises compliance with QPR’s Insider Guidelines. The CFO also maintains QPR’s insider register.
QPR Software Plc’s managers and their closely associated persons referred to in the MAR regulation have been requested to notify their transactions as of July 3, 2016.