Insider management

Aspo Plc complies with the provisions of the Market Abuse Regulation (EU) No 596/2014 and the Finnish Securities Markets Act (746/2012), as well as the rules, regulations and guidelines of the Finnish Financial Supervisory Authority, the European Securities and Markets Authority, and Nasdaq Helsinki Ltd (“Nasdaq Helsinki”).

In addition, Aspo’s Board has approved an Insider Guideline with the objective of supplementing the applicable legislation and establishing clear procedures and rules for the administration of insider matters, the disclosure of inside information, the maintenance of insider lists, and managers’ transactions, as well as to prevent the misuse of inside information.

The Group General Counsel is responsible for the guidance and supervision of insider matters.

Financial Information Recipients and Project-Specific Insider Lists

Aspo maintains a list of financial information recipients comprising persons who regularly participate in the preparation, drafting or communication of interim reports, half-year reports, financial statement releases and annual financial statements and who, during the preparation or drafting process and prior to disclosure, receive information concerning their forthcoming material content.

In addition, Aspo establishes and maintains, where necessary, project-specific insider lists of persons involved in the preparation of insider projects.

Persons discharging managerial responsibilities within Aspo and financial information recipients are subject to a 30-day closed period prior to the publication of an interim report, half-year report or financial statements. During the closed period, transactions in Aspo shares and other financial instruments, whether on their own account or on behalf of a third party, are prohibited. Persons entered in a project-specific insider list are likewise prohibited from trading in securities issued by the Company for the duration of the project.

Aspo’s list of financial information recipients and project-specific insider lists are maintained in an external service provider’s system.

Managers’ Transactions

Persons discharging managerial responsibilities within Aspo and persons closely associated with them must notify the Finnish Financial Supervisory Authority and the Company of transactions conducted in the Company’s financial instruments without delay. Aspo publishes the notifications it receives concerning such transactions as a stock exchange release withing three days of the transaction.

Persons closely associated with managers may request a copy of Aspo Plc’s Insider Guideline from the Company’s General Counsel.