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Disclosure policy

This disclosure policy describes the key operating principles that Eezy Plc (“Eezy” or the “Company”) adheres to in its investor relations and financial reporting. The disclosure policy will be reviewed and updated when needed.

In its communications, Eezy adheres to Finnish and the EU’s legislation, the rules of the Nasdaq Helsinki market maintained by Nasdaq Helsinki Ltd, the rules and regulations of the Financial Supervisory Authority and other authorities. Eezy also adheres to the Finnish Corporate Governance Code 2020 for Listed Companies, the Company’s internal policies and other guidelines.

Objectives and principles

The objective of Eezy’s communication with capital market representatives is to ensure that all market participants have simultaneously and without delay equal, correct and sufficient information on the Company and its business that can affect the valuation of the Company’s securities. The disclosed information must provide correct and sufficient information on Eezy’s operations. The principles of the disclosure policy concern Eezy Plc and its subsidiaries and associated companies.

Eezy’s key communication principles are timeliness, reliability, transparency, consistency and fairness. The Company communicates both positive and negative information clearly and extensively to all stakeholders. Eezy publishes press releases as soon as possible and simultaneously to the markets and relevant stakeholder groups.

Eezy’s official reporting language is Finnish. All stock exchange releases and press releases are published in Finnish and English.

Responsibilities and spokespersons

The Board of Directors addresses and approves the financial statement, report of the Board of Directors, half-yearly financial report and interim reports. The Board of Directors also approves significant stock exchange releases. In case the Board of Directors cannot be summoned immediately, the CEO or CFO together with one member of the Board of Directors are responsible for the implementation. Other stock exchange releases are approved by the CEO or CFO.

The CEO, group CFO or other person authorized by the CEO is entitled to issue statements on behalf of Eezy.

The group CEO and CFO are in charge of Eezy’s relations with representatives of the capital markets. The CFO is in charge of Eezy’s financial communications and reporting. The implementation and coordination of financial communications is centralized into group communications.

Group Communications, led by the Group’s Director of Communications and Marketing, is responsible for EezyEEZY’s media relations. Group Communications is also responsible for the Company’s communications related to sustainability matters. Individual business units or group-level functions are represented by the manager of the said business unit or a designated representative.

In crisis situations, the CEO is in charge of communications assisted by the Group’s Director of Communications and Marketing. Crisis communications is carried out by designated persons, with the goal of distributing information in a reliable, fast, clear, proactive and open manner.

Reporting units

Financial information is disclosed primarily on the group level and revenue information by service area.

Financial reporting and other regular reporting

Eezy publishes information regarding its financial position and development in interim and half-yearly financial reports, financial statements and the report of the Board of Directors. The Company publishes according to a previously announced schedule two interim reports, a half-yearly report and financial statements, which includes sustainability assurance, release annually.

Eezy also publishes a corporate governance statement and a remuneration statement annually.

If a financial report contains insider information (e.g., a significant write-down), it is described in the relevant financial report and stock exchange release, provided the financial report is published as an attachment to the stock exchange release.

Stock exchange releases

Eezy discloses, as soon as possible, all decisions, matters, and events that, in the Company’s own assessment, are likely to have a significant impact on the price of the Company’s financial instruments (e.g., shares) or related derivatives, in accordance with securities market legislation, regulatory guidelines, and other relevant stock exchange disclosure requirements.

For example, the following events, if significant for Eezy, are generally considered to affect the price:

Significant strategic changes;
Major corporate transactions, financing arrangements, and/or service expansions;
Significant organizational changes and changes in the composition of the board of directors or executive management, as well as changes in the auditor;
Major cooperation and service agreements;
Long-term investments;
Significant changes in the business environment;
Major litigation or other regulatory proceedings and decisions therein;
Decisions to implement share-based incentive programs; and
Profit warnings

Eezy discloses the insider information as soon as possible. The Company may with just cause delay disclosure of insider information, provided that all of the following conditions are met:

immediate disclosure is likely to prejudice the legitimate interests of Eezy;
delay of disclosure is not likely to mislead the public; and
Eezy is able to ensure the confidentiality of such insider information.

The decision on the delay of disclosure of information is made by the Board of Directors or an instance authorized by the Board of Directors. The Company has an internal process in place for continuously monitoring the conditions for delay and for disclosing the information without delay in a possible information leak situation. Eezy discloses the delayed information as soon as possible after the conditions for delay are no longer fulfilled.

The conditions for delaying the disclosure of insider information do not apply to profit warnings, which shall always be disclosed as soon as possible.

The profit warning announcement must clearly state the content of the profit warning (e.g., whether it concerns a deterioration or improvement of previously disclosed future outlooks) and the previously provided outlook to the market, if the Company has issued such guidance to the market.

Insider information is generally disclosed in a separate announcement, clearly indicating that the announcement contains insider information.

A stock exchange release is also used to disclose other information required to be published by a stock exchange release under the rules of the Nasdaq Helsinki marketplace (XHEL) maintained by Nasdaq Helsinki Oy and other applicable Nasdaq Helsinki Oy rules, even if such releases do not usually contain price-sensitive information. These matters to be disclosed via a stock exchange release include, among others:

Notice of the general meeting
Decisions of the general meeting
Share-based incentive schemes
Acquisitions and disposals of own shares
Managers’ Transactions

Press releases

Press releases targeted at general and industry media provide information about events related to the Company’s business that do not fulfil the criteria for a stock exchange release but are estimated to be newsworthy or otherwise of interest among capital market participants or the media. Company acquisitions that do not fulfil the criteria for a stock exchange release are primarily disclosed by means of a press release.

Outlook statement and profit warnings

Eezy shall annually disclose its outlook statement as part of the financial statement release and update the outlook when needed. The outlook statement is based on the Company’s current view assessment of the group’s and its business functions’ development. In uncertain market circumstances, Eezy’s Board of Directors can decide to withhold from issuing a statement.

A profit warning will be issued without undue delay if the Company’s view on the development of the Company’s financial outlook has changed significantly in a positive or negative manner and is likely to have a significant effect on the price of the Company’s securities. The assessment is based on a statement previously made by the Company or on what can reasonably be expected based on previously disclosed information.

Communication channels

The main source of information for real-time investor information is Eezy’s investor pages, which is made available for all investors equally. On its web pages, Eezy aims to provide reliable timely information to ensure that investors have sufficient information to support the valuation of the Company and its securities.

Eezy’s stock exchange releases are distributed simultaneously through Eezy investor pages and the release distribution platform. Stock exchange releases published by Eezy are made available for investors on the Company’s investor pages for at least five years after their release. Financial reports are maintained for at least ten years after their release.

Eezy also has different means and channels for disclosing information to stakeholder groups, such as different publications, interviews and public appearances.

The Company uses social media in its communications. Social media is not the primary communication channel for information under the disclosure obligation but supports the other channels.

Investor, analyst and media relations

Eezy actively meets with capital market and media representatives and responds to queries submitted by investors, analysts and the media via phone or email without undue delay. The Company can arrange meetings with the media and analysts in connection with financial results. Eezy arranges, when needed, background information events, such as the Capital Markets Day around different themes. Material from the events shall be published on the Company’s website before the start of the event.

Communications with investors and analysts is carried out by the CEO and CFO of Eezy. Media events are coordinated by group communications.

The objective of the meetings is to provide information on Eezy and its operating environment. During meetings, information is provided within the limits of previously publicly disclosed information and accurately in accordance with such information. New, yet undisclosed information or complementary information that in conjunction with previously disclosed information could constitute information which could affect the price of Eezy’s securities shall not be provided at these meetings in which case Eezy could come to have illegally disclosed inside information.

Eezy does not provide analysts with information in meetings that has been updated or differs from the information already disclosed by the Company. In meetings, analysts are not presented with a broader view of changes in Eezy’s operating environment that are not generally known to the market.

Materials used in investor and analyst meetings and earnings releases are published as promptly as possible to other investors on Eezy’s investor pages. Analyst meetings and information sessions for earnings releases are aimed to be organized openly via the internet for all interested participants, if it is justified for Eezy’s operations or market information.

Eezy does not comment in meetings with analysts on the Company’s value creation, the value development of its financial instrument (e.g., shares), analyst forecasts, or the level of results compiled in the consensus forecast. If Eezy finds in meetings that analysts do not have a correct understanding of Eezy’s financial development based on previously disclosed information, the board will assess the need to correct the misunderstanding with a stock exchange release, based on a proposal from the CEO or CFO.

Eezy does not favor individual analysts in meetings or distribute analyst reports to the investment community. Eezy may present consensus forecasts made by analysts on the Company’s investor pages, but in such cases, this information is presented on Eezy’s investor pages in a way that clearly indicates that it is not material prepared or confirmed by the Company. The investor pages may also list the analysts following Eezy.

Analyst and consensus forecasts

Eezy monitors analysts’ statements and estimates on the Company. Analysts’ opinions, estimates and forecasts are their own and do not represent or reflect the opinions, estimates or forecasts of the Company or its management. The Company does not comment on statements or estimates made by analysts.

Upon request, the Eezy’s investor relations function may review an analysis or report made by an analyst, but only with regard to the correctness of the information and based on disclosed information. In such cases, the Company must ensure that it does not intentionally or unintentionally confirm or comment on the conclusions or assessments of the analyst.

If Eezy discovers that analysts have misunderstood the key information disclosed by the Company and that this information, either on its own or as part of a larger context, could materially affect the value of Eezy’s shares, the Board of Directors must, upon the proposal of the CEO or CFO, assess the need to correct the market’s misunderstanding. The analyst’s misunderstanding cannot be corrected in this situation by providing the corrected information to one or more analysts alone.

Rumours and information leaks

Eezy issues statements on its own operations and generally does not comment on the operations of its competitors, suppliers or customers.

Eezy does not comment on market rumors, unless it is necessary to correct relevant or clearly inaccurate information. Eezy may consider publicly disclosing a stock exchange release to correct clearly incorrect or misleading information that is likely to have a significant effect on the price of the Company’s share.

In the event that confidential and relevant information has leaked to a third party outside the Company’s statutory insiders, the Company will disclose the matter as a stock exchange release as soon as possible.

Silent period

Eezy adheres to a 30-day silent period in its investor and media relations before the publication of interim reports, a half-yearly financial report or financial statement release. During this time, the Company will not meet with representatives of capital markets or media, nor comment on the Company’s financial position, markets or outlook. The publication dates of financial results are disclosed before the start of the upcoming accounting period, and they are made available in the investor calendar of Eezy’s investor pages.

If an event during the silent period requires immediate publication, Eezy will publish the information without delay in accordance with regulations regarding the disclosure obligation and can comment on the event in question.

Monitoring and Interpretation of the Disclosure Policy

The CEO is responsible for the monitoring and interpretation of the disclosure policy. The CEO or a person designated by the CEO will provide additional instructions on the practical implementation of the disclosure policy as needed. The CEO has the right to deviate from the disclosure policy in individual cases for compelling reasons, within the framework of laws and regulations, after consulting the Chairman of the Board

The Board of Eezy Plc has approved this Disclosure Policy.