MARKET ABUSE RULES (“MAR”) IN RELATION TO PDMRs
Section 19, MAR lays down rules regarding transactions carried out by Person Discharging Managerial Responsibilities (PDMR) and their associated persons. In this context, PDMR is understood to mean a person in Flexion Mobile PLC’s (Company) leadership, administration or supervisory groups, or executives who are not included in any of these groups but have regular access to insider information and authority to take decisions on managerial level, which affect the future development and prospects of the Company.
Under Section 19, MAR Flexion Mobile is obligated to: i) keep a record of all persons in key positions and their associates; ii) in writing remind persons in key positions of their obligations under Section 19, MAR. Under Section 19, PDMRs are obligated to: i) without undue delay inform the Company and the Financial Conduct Authority (FCA) about changes in shares issued by Flexion Mobile and other related financial instruments, never later than 3 business days after a day of transaction; and ii) in writing remind associates of their obligations under Section 19 MAR
Under Section 19, the Company is obligated to make PDMR related transaction public no later than 3 business days after a day of transaction. As the FCA’s PDMR register is not public, the Company will present PDMR related transactions on its web page to disclose them publicly. The transaction reporting is restricted by a threshold value of EUR 5,000 per calendar year per PMDR. The transaction that reaches or exceeds this threshold and all subsequent transactions during the calendar year shall be reported.
PDMRs are allowed to trade securities issued by the Company during a 30 day window following the disclosure of quarterly and annual reports and financial statements subject to not using any insider information. PDMR’s are barred from making short term gains on trades in securities issued by the Company.
| Name | Position | Date of Transaction: | Date of Notification to Company: | Number of Shares Purchased: | Number of Shares Sold: | Share Price (SEK): |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 02/07/2018 | 06/07/2018 | 28,000 | 8.32 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 03/07/2018 | 06/07/2018 | 55,020 | 8.50 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 04/07/2018 | 06/07/2018 | 16,980 | 8.24 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 25/11/2019 | 27/11/2019 | 26,340 | 9.06 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 26/11/2019 | 27/11/2019 | 19,219 | 9.10 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 27/11/2019 | 27/11/2019 | 4,441 | 9.09 | |
| Barn Storm Media AB | Associated to Claes Kalborg (Director) | 3/12/2019 | 4/12/2019 | 14,800 | 9.00 | |
| Barn Storm Media AB | Associated to Claes Kalborg (Director) | 10/12/2019 | 12/12/2019 | 14,800 | 9.00 | |
| Niklas Koresaar | CFO | 17/12/2019 | 17/12/2019 | 10,000 | 7.05 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 17/12/2019 | 17/12/2019 | 19,500 | 7.29 | |
| Niklas Koresaar | CFO | 18/03/2020 | 18/03/2020 | 7,500 | 5.50 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 11/06/2020 | 12/06/2020 | 50,000 | 9.39 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 03/12/2020 | 03/12/2020 | 279,720 | 14.30 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 03/12/2020 | 03/12/2020 | 699,300 | 14.30 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 03/12/2020 | 03/12/2020 | 7,013,984* | 0 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 15/12/2020 | 17/12/2020 | 5,576,222** | 0 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 29/12/2020 | 29/12/2020 | 1,437,762** | 0 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 07/01/2021 | 07/01/2021 | 1,437,762* | 0 | |
| Barn Storm Media AB | Associated to Claes Kalborg (Director) | 11/02/2021 | 13/02/2021 | 4000 | 21.56 | |
| Barn Storm Media AB | Associated to Claes Kalborg (Director) | 12/02/2021 | 13/02/2021 | 2000 | 21.8 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 23/02/2021 | 23/02/2021 | 1,437,762** | 0 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 27/05/2021 | 27/05/2021 | 100,000 | 12.85 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 27/05/2021 | 27/05/2021 | 10,509 | 12.46 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 24/08/2021 | 24/08/2021 | 100,000 | 16.25 | |
| Mikael Pawlo | Director | 24/08/2021 | 24/08/2021 | 100,000 | 16.25 | |
| Mikael Pawlo | Director | 25/08/2021 | 25/08/2021 | 12,000 | 16.90 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 18/11/2021 | 18/11/2021 | 50,000 | 16.24 | |
| Mikael Pawlo | Director | 18/11/2021 | 18/11/2021 | 6,535 | 15.30 | |
| Palmstierna Invest AB | Associated to Carl Palmstierna (Chairman) | 18/05/2022 | 18/05/2022 | 50,000 | 14.11 | |
| Jens Laurtizson | Director / CEO | 9/9/2022 | 9/9/2022 | 74,000 *** | GBP 0.32 *** | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 23/9/2022 | 23/9/2022 | 25,000 | 15.98 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 29/11/2022 | 29/11/2022 | 2,100,000* | 0 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 30/11/2022 | 30/11/2022 | 10,000 | 15.53 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 30/11/2022 | 30/11/2022 | 10,000 | 14.84 | |
| Niklas Koresar | CFO | 09/12/2022 | 09/12/2022 | 437,500 *** | 6.98 | |
| Adrian Kotowski | Head Influencer Marketing | 12/12/2022 | 12/12/2022 | 8,000 | 13.79 | |
| Mobile Sensations Ltd | Associated to Jens and Per Lauritzson (Directors) | 13/12/2022 | 13/12/2022 | 2,100,000** | 0 |
* Lending of shares to enable the issuing agent to settle a fund raise before the issuing company (Flexion Mobile Plc) have time to send shares to the issuing agent. The shares will be repaid after the issuing company have issued shares to the issuing agent i.e. the lending of shares has no economical impact on the share lender.
** Repayment of shares by the issuing agent as described above.
*** EMI Staff Options