INSIDER administration

Aspo Group complies with the EU’s Market Abuse Regulation (EU No 596/2014) and regulations issued pursuant to it, and other applicable guidelines, including the insider
guidelines of Nasdaq Helsinki Ltd.

Permanent insiders of Aspo Plc include the members of the Board of Directors, the Group Executive Committee, the auditor and other individuals who have regular access to insider information. Individuals working in managerial positions at Aspo Plc include members of the Board of Directors and the Group Executive Committee. When necessary, Aspo establishes and maintains project-specific insider lists of persons involved in projects involving insider information.

A closed period of 30 calendar days before the publication of interim reports, half-year financial reports and financial statements applies to individuals working in managerial positions at Aspo Plc and to permanent insiders. During the closed period, the persons are prohibited from trading on Aspo’s shares and other financial instruments on one’s own account or for the account of a third party. Furthermore, individuals entered in project-specific insider lists cannot trade in financial instruments / on securities issued by the company during the specific project period. Individuals working in managerial positions at Aspo Plc and their related parties must report any business transactions associated with the company’s financial instruments to the company and to the Finnish Financial Supervisory Authority.

The SVP, Legal and Sustainability, is responsible for the control and monitoring of insider issues. Aspo Plc’s insider register, and project- specific insider lists are maintained in Insider Elements- service, an application service provided by Euroclear Finland for its customers to maintain registers associated with insider administration.