Insider administration

The Company complies with the Insider Guidelines of Nasdaq Helsinki. It is available for review on www.nasdaqomx.com.

Trading Prohibition

Trading in the Company’s financial instruments is always prohibited, when the person is in possession of inside information related to the Company or its financial instruments.

The Company's top managers are always prohibited from trading in the Company's financial instruments during 30 days before the publication of an interim report and a financial statement bulletin, including the day of publication (the so-called closed window), regardless of whether the person possessed inside information that time. If the financial statement bulletin does not include all significant information, the closed window is also applied before the financial statement is published. During other times i.e. as of the day following the publication of interim reports and financial statement bulletin there is the so-called open window during which top managers are allowed to trade provided that they do not possess inside information at such time and that they have gone through the internal checking process.

The closed window also applies to persons who participate in the preparation and drafting of interim reports and financial statement bulletins.

Information on the shareholding of top management is available in the Management shareholding section.

Insider Projects

A person entered into a project-specific insider list must not trade in the financial instruments issued by the Company or disclose inside information to a person outside the project during the project. It must be noted that during the insider project it is also prohibited to trade in financial instruments of another issuer that may relate to the project.

The trading restrictions applicable to persons entered into a project-specific insider list expire when the Company has (i) published the matter through a stock exchange release in a detailed enough manner or (ii) separately announced that the project has been terminated.

Control

The Company ensures compliance with insider holding guidelines by regularly reminding insiders of permitted trading windows. HKScan’s Group administration maintains and manages the insider lists.

HKScan has set up a whistleblowing channel in order for the employees of the Company to have means of notifying cases in which they have reasonable grounds to suspect that somebody employed by HKScan has breached legislation regarding security markets (The Finnish Securities Markets Act and the MAR) among others.

The notifications shall be investigated by a person authorised by HKScan. If a breach is suspected or the breach can be proved the case is moved to the relevant authorities.