Closed periods

Pursuant to the ITP a Manager is: each member of the Management Board and Supervisory Board; and each senior executive, who is not a member of the Management Board or the Supervisory Board, who has regular access to Inside Information and who has the power to take managerial decisions affecting the future developments and business prospects of InPost.

Pursuant to the ITP an Insider is: an Employee, not being a Manager, or other person who has access to Inside Information in the exercise of his or her duties or has been designated as such by the Compliance Officer.

Inside information is defined as any information pertaining directly or indirectly to one or more issuers or one or more financial instruments, which has not been publicly released and which, if publicly released, would significantly affect the price of the issuer’s shares, derivative rights attached thereto or other financial instruments related to such shares.

In line with the Market Abuse Regulation ¹ and the ITP, persons who have access to inside information prior to its publication are expressly forbidden to:
 

• use the inside information;
• recommend, on the basis of that information, that another person acquire or dispose of financial instruments;
• disclose confidential information to unauthorized persons and entities;
• engage in trading in financial instruments issued by the Company and derivative instruments attached thereto, attempt to engage in such trading, or modify or cancel acquisition or disposal orders following receipt of confidential information.

¹ REGULATION (EU) No 596/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 Apr 2014 on market abuse (market abuse regulation) and repealing Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC