Insider Policy

for trade in Financial Instruments in FINGERPRINT CARDS AB (PUBL)


1.1 A prerequisite for trade in securities is that the public has confidence in the securities market. Similarly, how employees and other stakeholders of Fingerprint Cards AB (publ) (“the Company”) conduct trade in securities in the Company is of the greatest significance to the market’s confidence in the trade and the Company. In light of this and as a complement to Regulation (EU) of the European Parliament and of the Council No 596/2014 on market abuse (“MAR”) and the provisions in the Act (2005:377) on Penalties for Market Abuse involving Trade with Financial Instruments (the “Market Abuse Act”) and the Act (2000:1087) concerning Reporting Obligations for Certain Holdings of Financial Instruments (the “Reporting Obligation Act”), the Board of Directors of the Company (“the Board”) has established this policy. The policy applies to all persons discharging managerial responsibilities, which is a person who is (a) a member of the administrative, management or supervisory body of the Company; or (b) a senior executive who is not a member of the bodies referred to in (a), who has regular access to inside information relating directly or indirectly to the Company and power to take managerial decisions affecting the future developments and business prospects of the Company This policy shall be applicable in addition to that stipulated in MAR, the Market Abuse Act and the Reporting Obligation Act, also known as insider legislation.

1.2 Financial instruments are deemed to be financial instruments according to Directive (2014/65/EU) of the European Parliament and of the Council on Markets in Financial Instruments, which includes shares or debt instruments or derivatives, or other financial instruments connected to these, including, but not limited to, subscriptions rights, interim certificates, options certificates, convertible debt instruments, debt instruments combined with options for subscription for new shares, participation certificates, stock options, stock forward contracts. Also including, but not limited to, pledge assets, lending, stock in endowment insurance and stock under discretionary management.

1.3 All individuals covered by this policy shall study and confirm this policy. The provisions found in this policy cannot, however, exhaustively address all possible situations. Accordingly, it is incumbent on all individuals concerned to be aware of and comply with insider legislation applicable at all times.


2.1 MAR and the Market Abuse Act contains rules regarding a prohibition to conduct trade. In brief, these rules mean that individuals with awareness of information that is not public or generally known and that is likely to affect the price for which financial instruments are traded on the market (“Insider Information”) may not, on their own behalf or on behalf of another party, buy or sell such instruments or influence somebody else to do so. In addition, MAR and the Market Abuse Act contains a prohibition against disclosing Insider Information, and provisions regarding improper market influence, entailing a criminalization of certain false or misleading actions or the dissemination of false or misleading information.

2.2 MAR and the Reporting Obligation Act contains an obligation for persons discharging managerial responsibilities and persons closely associated  to report notifiable transactions to the Financial Supervisory Authority and the Company within three (3) days of the transaction. Persons discharging managerial responsibilities are also obliged to notify persons closely associated about their obligations according to the legislation and to retain a copy of the notification. The Act also contains rules regarding a general prohibition to conduct trade for persons discharging managerial responsibilities, entailing that trade may not be conducted in shares in the Company for thirty (30) days prior to the publication of an ordinary interim report. MAR and the Reporting Obligation Act also includes rules on the keeping of a list of individuals with access to Insider Information, a so-called logbook.


3.1 The rules pursuant to this Section 3 apply alongside of and in addition to the rules pursuant to legislation applicable at all times concerning a prohibition of conducting trade in financial instruments in the Company.

3.2 Trade in financial instruments in the Company is prohibited for thirty (30) days prior to the publication of an ordinary interim report.

3.3 In addition to what is stipulated in Section 3.2 above, anyone with access to Inside Information may not conduct trade in financial instruments in the Company.

3.4 A prohibition on short-term trade applies for all individuals covered by this policy. This prohibition means that financial instruments in the Company may be transferred no earlier than three months after a corresponding number of financial instruments of the same class were acquired.

3.5 Despite the trade prohibition in Sections 3.2 and 3.4 above, permission to conduct trade may, in addition to what is stated in MAR and the Market Abuse Act, be granted by way of exception by the Company’s Compliance Officer.

4.1 Individuals who want to sell or buy financial instruments in the Company must apply to the Company’s Compliance Officer no later than five (5) days before each occasion that they want to conduct trade.

4.2 An application according to Section 4.1 shall state the highest number of financial instruments that are requested to be purchased or sold on each occasion.

4.3 If the Company’s Compliance Officer provides notice that the purchase or sale may take place as applied, such trade may only be conducted no later than three (3) trading days after the date of the notice (or no later than another date as indicated by the Company’s Compliance Officer). Thereafter, if the individual wants to conduct further trade on another occasion, a new application must be made in accordance with the above.


Jan Wäreby
Urban Fagerstedt
Katarina Bonde
Carl-Johan von Plomgren
Lars Söderfjell
Peter Carlsson
Michael Hallén
Åsa Hedin
Tomas Mikaelsson