Insiders

Sponda complies with the Insider Guidelines issued by Nasdaq Helsinki Ltd. These recommend that insiders wishing to trade in the company’s shares do so only at times when the market has the fullest possible information on matters that may have a material impact on the share price. Accordingly, Sponda’s insiders are not permitted to trade in Sponda’s securities for a period commencing 21 days before the company publishes its interim reports or annual results.

The company’s statutory public insiders are its Board of Directors and the Executive Board and the auditors. In addition, the company maintains a company-specific insider register, comprising a permanent company-specific insider register and a project-specific insider register. The permanent insider register lists the names of individuals who, pursuant to their position or duties, have regular access to insider information. The project-specific insider register lists the names of individuals to whom the company discloses specific insider information pertaining to a particular project. The insider register maintained by Euroclear Finland Oy includes information on the holdings of the individuals in the company’s public insider register subject to the disclosure obligation. The company’s public insider register is also available on its website at www.sponda.com.