Investor Communication and its Regulation

“Might be” was the essential addition that was missing from your message (deliberately, of course)

27 years ago, IR might have hinted in advance to analysts and portfolio managers before the earnings release about the range where the results would land, allowing them to adjust their forecasts. Perhaps someone even exploited insider information.

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It’s probably only been 5 or 6 years since Nokian Tyres (if I remember correctly, I might be wrong about the company) mentioned in a pre-silent analyst call that the estimates are a bit too optimistic. :sweat_smile:

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How about this:
“For the community’s information: I received an email today at hh:mm from xxx.yyy@qt.com, informing that Xxx Yyy is moving to other duties.”

Vs.

“Qt Group’s CFO is resigning.”

I’d argue that it would be quite difficult to twist the first one into misuse of inside information.

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Hi Mikael! It’s nice that you commented on this specific case in addition to the guideline! I respect this guideline of yours, and also the fact that it is strictly followed. But was this even such a situation in the first place? At least based on what Atte wrote in the Qt thread, I understood him to say that he had made the judgment that this is not inside information, but did not see it as appropriate to comment on the matter. Both Qt and OP indeed seem to have reached the same conclusion (that it is not inside information) on their part, as stated above.

In addition to what I quoted above, Atte justified this, as I understand it, with good manners (and mutual respect between finance brothers?? using the term “kosher”), but nothing in that gave the impression that he considered this to be inside information to any extent.

If I have misunderstood, and he actually was uncertain about whether it was inside information or felt the matter was somehow in a gray area, in that case, I absolutely understand his decision, and then it was without a doubt the right decision. But based on what he wrote himself, I have a slightly different impression.

The decision was certainly difficult, and above all, made quite quickly in the middle of the busiest earnings season. I’m not throwing stones, whatever the situation. And of course, thumbs up and kudos to Mikael for the CEO taking the lead on this matter.

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Real (good) investor communication from Inderes: “The Swedish magazine Affärsvärlden wrote yesterday, based on its reliable sources, that Telia has a sales process underway for TV4. According to Affärsvärlden, the buyers involved in the negotiations include at least Schibsted, Bonnier, and Egmont. The price tag is reported to be 5 billion kronor or even less, which would be less than half of the purchase price paid by Telia in 2019.”

And then, imagined good investor communication: “QT’s CFO Jouni Lintunen is moving to another employer, reports Osuuspankki in its morning review. According to information obtained by Osuuspankki, I.A.R. Systems’ CFO Ann Zetterberg has been appointed as the interim CFO to replace Lintunen. QT has not issued a press release regarding the matter.”

It’s no more difficult than that.

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The saddest part about this is that Inderes cannot admit to making a mistake. That would have settled the matter. Finns are a forgiving people. The first principle of crisis communication is: Don’t dodge and make up excuses. Otherwise, you only make the situation worse.

It brings to mind those Finnish politicians who never admit to having messed up. The best way to lose trust is to claim until the very end that you acted correctly, even when most people disagree.

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Yep, and a potentially catastrophic outcome for the brand. This above all creates the impression that there is a lot of silent information circulating in financial circles, and that the unwritten rule of the brotherhood is that these things are not shared with retail investors (because it’s “not kosher”).

In Inderes’ history, the company’s existence has been justified by the very fact that there used to be a lot of information shared only with analysts that was not available to the public. Has Inderes become part of that dark system it was once founded to oppose? This is an image that should definitely be avoided at all costs. I own [shares].

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97% of forum users won’t remember the whole thing in 3 months unless specifically reminded.

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Inside information is defined as follows.

Didn’t Atte fear a share price reaction there, so it can be read between the lines that they were in a very gray area, even if he didn’t want to call it inside information.

Based on the definition, I would call this inside information myself. It was certainly to be expected that there would be a price impact when the CFO, who served as a key person in a company in crisis, leaves in the middle of an integration process while the market is already nervous about whether a profit warning (negari) is coming and what the forecasts for this year will be.

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To me, that reasoning looked purely like the fear of a shitstorm was the reason for withholding information, not the fear of publishing inside information. We’ll likely never get the final truth. To my eyes, however, the matter looked like moving the goalposts, when

  1. first the analyst states that there is no inside information
  2. the community builder implies with a meme that the options were illegal publication of inside information or the community’s wrath (I don’t see community wrath anywhere, by the way)
  3. then the CEO comes to say that inside information must not be published regardless of how it was obtained, and that the analyst has acted according to instructions.

Inderes’s communication doesn’t get full marks here either, and in my opinion, the analyst and the CEO are giving contradictory messages. Mistakes happen when things get messy, and I am at least as forgiving as the Finnish public in general, but a clarification would be in order.

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Quite an uproar on the forum. There is only one party to blame here, and it is not Inderes or even OP. The fault lies entirely with QT, and the responsibility can be pinned on Lintunen himself.

Inderes couldn’t have handled this without a stir if the Company doesn’t know how to manage its own affairs. The forum’s darling stock stirs up emotions, and nothing similar would have happened with Rapala or, for example, Konecranes, beyond a few scolding messages.

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I don’t see any hate on the forum either, only criticism. It may be that things were handled correctly from some perspective, but this certainly brings back those unpleasant feelings about how stock picking isn’t worth it when some players in the market are in a better position than others. Regardless of who is at fault, the consequences will likely fall on Inderes.

As a side note, I don’t own/haven’t owned Qt and I was even one of the lucky ones who already read about the matter in OP’s review this morning. This kind of inequality is just frustrating.

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This is still unclear to me: where would that fuss towards Inderes have come from if they had also disclosed the matter in their morning report, just like OP did? Even Atte, in his original response, referred to some potential shitstorm, but I really don’t understand where or why such a thing would have come from?

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I think you’re overinterpreting a little, though I understand what you mean. Let’s break it down a bit more.

Indeed not, because it could have been interpreted as the disclosure of inside information.

Yes, the price reaction could have confirmed that Inderes was guilty of disclosing inside information, which could have resulted in a shitstorm.

True, it is not DIRECTLY inside information. So the situation is subject to interpretation, and with a more stable company in a different situation, it would be a minor matter without an expected price reaction, in which case it wouldn’t be inside information. In this case, Atte felt it was better to play it safe and didn’t write about it.

The only contradiction in Inderes’ communication, as I understand it, relates to that last sentence, if interpreted such that Atte was certain the information in question was not inside information. In my opinion, Atte’s message doesn’t convey such certainty; rather, they wanted to play it safe and treat the information as inside information.

OP’s analyst took a risk, but I don’t think there will be any consequences for him.

Karo was also, in my opinion, surprisingly brazen in his comment. It couldn’t be said much more clearly that he feels publishing illegal insider information is outright his duty.

My first thought when reading OP’s review was: guidance won’t be met. Second thought: differing opinions on the earnings forecasts for the coming year. Third thought: if I owned the stock, I should probably sell.

OP’s analyst did exactly what an analyst is supposed to do: reported the news.

If I were an analyst myself and heard information that presumably has an impact on the share price, I would feel it my duty to my clients to tell them.

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At the risk of repeating my repetition’s repetition, I repeat that Inderes could have come out on the matter as a second party, in which case its role would have simply been to repeat already public information. As I wrote above:

The fact that Inderes does not bring already published relevant information to the attention of investors regarding a company that it otherwise hypes more than almost any other, is purely and simply poor performance of their duties.

Referring to my previous quote regarding Telia, would it be anything new for the media to report on a company’s plans before the company itself makes an announcement? And for some reason, handling these media reports is not a problem for analysts, even if the company’s official press release on the subject hasn’t been received yet.

As for journalists and the media, it’s worth remembering the difference between leaking insider information to the media and the media reporting on the insider information leaked to it.

Since I’m not a lawyer, I’ll leave sorting out that side of things to others. However, I think it’s clear: 1) Analysts also regularly comment on market rumors that fall under inside information published by the media. Usually, of course, with an emphasis on the reliability of the media outlet, so not every news item from MV-Lehti qualifies as a source; 2) The morning report published by Osuuspankki, which has over three million customers, is comparable in its public exposure to many financial media outlets.

The original publisher of the information obviously has a major responsibility, at least in terms of verifying the authenticity of the message. Spoofing an email sender is the easiest thing in the world. If I were to send an email to analysts pretending to be Mikael Rautanen, thanking them for the years together and saying I’m stepping down from Inderes because Summa Defence bought the company in a share swap, or because I want to pursue a meaningful career as the manager of the Inderes House Band, it wouldn’t be desirable for an analyst to write a morning report news piece based on that.

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Hesari wrote an article about this yesterday (no paywall):

I got the impression from the article that Qt had no intention of announcing Lintunen’s departure separately:

According to Qt’s view, this wasn’t even a matter subject to disclosure obligations, which I disagree with.

The ones who messed up were still Qt and Lintunen, but I think Inderes should have also informed the public about it.

That information spread to all the brokerage firms’ most important clients immediately after the email; OP was the only one who shared the same information with retail investors.

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We are just left guessing here what Atte meant. However, I think it’s indisputable that, at least in that post, he didn’t justify the non-disclosure with the MAR regulation or inside information at all. Instead, he listed other reasons for not publishing.

He also referred to the company’s obligation to disclose non-inside information as well [point 3.5]. Separately, he even stated that this is not inside information. If the purpose of the post was the opposite, I am even more firmly of the opinion that the communication has not been successful. A clarification would be in order instead of us having to guess and examine every word here like in a crime lab.

If the real reason truly was the MAR regulation (i.e., inside information), it would have been good to state that already in the original post. Or even afterwards! This hasn’t been done, however, which is very confusing. I can’t think of any reason why this wouldn’t be expressed if the situation really was this.

Karo, on the other hand, is far too close to journos to understand that it is not legal to publish all information. But that is a different story :slight_smile:

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