Risks related to Saga Furs Oyj’s operations are divided into business risks, hazard and property risks, financial risks and operational risks. Within these risk categories, the Company has specified economic and exchange rate fluctuations, image risks and political risks related to fur breeding and pelt trading, changes in the production of fur pelts and financial risks as the major risks and uncertainties at the moment.
The company seeks to manage and limit the risks by applying a consistent policy, which aims to ensure appropriate risk identification, assessment, management and supervision throughout the Group. It is an integral part of the Group’s planning and management process, decision-making, day-to-day management and operations and supervision and reporting procedures. The risk management process yields information on risks and on the progress of risk management measures, which forms the basis for taking corrective measures if necessary or considering strategy changes.
However, should the risks materialize, they could have a significant adverse effect on Saga Furs Oyjs business, financial position and results.
Due to its small size, the Company does not have a specific organisation for internal control. The Board of Directors familiarises itself with the auditors’ Control Audit Plan and may possibly give an additional report in regard thereto. In connection with the Control Audit, the auditors analyse the company’s and the Group’s accounts, Group-level interim reports and the company’s receivables with the objective of ensuring that the reports published by the company provide correct information about the company’s finance to a sufficient degree. In addition, in connection with the Control Audit, the auditors suggest (and have suggested) ways to develop and improve the company’s internal controls. Based on this, the Board has required and requires the management of the company to develop operational processes and controls.
Insider Management
The Board of Directors of Saga Furs Oyj approved the Company’s Insider Guidelines on 28 June 2016, and they entered into force on 3 July 2016. The Insider Guidelines are based on the Market Abuse Regulation (EU No. 596/2014, “MAR”) and the laws and regulations issued pursuant to it, as well as the rules and Guidelines for Insiders of Nasdaq Helsinki Ltd, which Saga Furs is required to comply with as a listed company. Saga Furs complies with MAR regulations on matters such as insider projects, technical procedures for the disclosure and postponement of disclosure of inside information, the format and model of the notification and disclosure of transactions by executives and the format and method of updating insider lists.
Saga Furs has defined the members of the Company’s Board of Directors, the CEO and the members of the Management Group, including their related parties in accordance with MAR, as persons subject to the reporting obligation for transactions carried out with the Company’s financial instruments. Executives are subject to a trading restriction (closed window) on Saga Furs’ financial instruments during the 30 calendar days prior to the publication of the company’s financial statement bulletin or half-year financial report. In addition to executives, the company has defined a 30 calendar day trading restriction (closed window) for persons who regularly participate in the preparation of half-year financial reports, financial statement bulletins and financial statements.
Insider information and lists
Saga Furs’ insider administration draws up and updates insider lists electronically. In addition to the individual insider lists (project-specific insider list), Saga Furs has a supplementary section on permanent insiders. The group of permanent insiders only includes those persons who, based on their duties, are considered to have continuous access to all inside information. Permanent insiders are considered to be aware of all inside information. Saga Furs must inform permanent insiders immediately of the establishment of a new insider project. Persons who have inside information about a project, including any external advisors and experts, are recorded in a project-specific insider list.
Insider lists are maintained using an electronic procedure that meets the applicable requirements and is prepared and/or approved by the Financial Supervisory Authority or another appropriate party. Insider lists are not public and are not made available to the public.
The insider administration informs a person included in an insider list in writing of their insider status, the resulting obligations and any consequences related to the breach of the obligations. A person entered in a project-specific insider list is notified of the termination of the project and the closure of the project-specific insider list.
The Group’s HR and IT Director is in charge of insider issues at Saga Furs.
Trading restrictions (closed window)
Persons in executive positions and other permanent insiders, as determined by Saga Furs, must schedule their trading in financial instruments in such a way that trading does not undermine confidence in the securities market.
Persons in executive positions and any other permanent insiders may not carry out transactions on their own behalf or on behalf of a third party during a closed period that always starts 30 days before the date of publication of the relevant financial statement bulletin and half-year financial report and ends 24 hours after the publication of the Group’s interim report, half-year financial report or financial statement bulletin.
In accordance with Nasdaq Helsinki Ltd’s Guidelines for Insiders, Saga Furs stipulates that persons involved in the preparation, creation, audit or disclosure of Saga Furs’ financial reports may not carry out transactions on their own behalf or on behalf of a third party during the closed period.
The trading restriction also applies to persons who are under the guardianship of persons covered by the trading restriction. A person subject to a trading restriction is also responsible for complying with the trading restriction when the management of their securities and other financial instruments is entrusted to another person, such as an investment manager.
Duty of the management and their related parties to report and disclose transactions
Persons in managerial positions and their related parties must notify Saga Furs and the Financial Supervisory Authority of all transactions they carry out on their own behalf with respect to Saga Furs’ shares, debt instruments or derivatives or other related financial instruments. The reporting obligation applies to transactions carried out on any marketplace or outside marketplaces.
The lower limit for the notification obligation is EUR 20,000 (twenty thousand) per calendar year.
Updated: June 2025