Insider issues

Inderes has an Insider Policy approved by its Board of Directors for the company's employees and members of the Management Team and Board of Directors, which includes rules and procedural obligations concerning, among other things, the postponement of insider information, insider projects, trading restrictions, management transaction reports and the monitoring of insider matters. The purpose of the Policy is to ensure that inside information is handled carefully without compromising its confidentiality, to prevent unlawful disclosure of inside information and insider dealing, and to enhance market transparency and confidence.

The Code of Conduct and the obligations of the Insider Policy are in addition to the rules and regulations that are binding on the company and with which the company complies in its operations, such as the Market Abuse Regulation (596/2014/EU as amended) and the regulations issued thereunder, domestic regulations, including Criminal Code (39/1889, as amended) and the Securities Markets Act (746/2012, as amended), the guidelines of the Financial Supervisory Authority and ESMA, as well as Nasdaq Helsinki Oy's Insider Trading Guidelines and the rules of the Nasdaq First North Growth Market.

The company has appointed a person responsible for insider matters, along with their assistant and deputy, to manage insider information. The CFO of Inderes is the designated person responsible for insider matters. The insider administrators also ensure that trading by insiders, directors and their related parties and persons involved in performance reporting follows the regulations.

If the company decides to postpone the disclosure of insider information, it will maintain a project-specific insider list of all individuals with inside information related to the project. The company does not maintain a permanent insider list in aside from these the project-specific insider lists.

Closed period add

During the closed period, members and deputy members of the Board of Directors of Inderes, the CEO, the Executive Vice President, members of the Management team, and individuals involved in the preparation of Inderes' financial reports are prohibited from directly or indirectly conducting transactions involving Inderes' financial instruments (such as shares, debt instruments, derivatives, or other related financial instruments) for their own account or on behalf of a third party. The closed period begins 30 calendar days prior to the release of Inderes' business reviews and financial statements and ends on the day following the release of said result release.

Management transactions add

Directors of Inderes, as well as the individualsand entities related to them, must report to both Inderes and the Financial Supervisory Authority ("FIN-FSA") all transactions relating to Inderes' financial instruments (shares or debt instruments or related derivatives or other financial instruments) carried out on their own account. Managers with notification obligations include the members and deputy members of Inderes' Board of Directors, the CEO and deputy CEO, and the members of the Management team. Inderes maintains a list of directors subject to notification obligations and persons and entities related to them.

Inderes will publish the notified transactions in a company announcement without delay and no later than three business days after the transaction has taken place.

Notification of management transactions add

An issuer’s managers and persons closely associated with them are obliged to notify the issuer and the FIN-FSA of their transactions relating to said issuer’s shares, debt instruments, derivatives or other financial instruments (Article 19 of MAR).

More detailed information on the notification obligation can be found here: https://www.finanssivalvonta.fi/en/financial-market-participants/capital-markets/issuers-and-investors/Managers-transactions/

Time limits for notification

• Notification of the transaction must be made without delay and always within three (3) working days of the transaction.

• Inderes is obligated to publish the transaction notification as a stock exchange release within two (2) business days of receipt of the transaction notification.

Instructions for submitting transaction notifications:

1. Fill out the transaction notification form in the Financial Supervisory Authority e-service

Before sending the transaction notification to the Financial Supervisory Authority, save the form as a PDF file and send the PDF as an attachment to the email address ir@inderes.fi.
Detailed instructions on how to complete the declaration can be found on the website of the Financial Supervisory Authority.

Information required for the notification:

Inderes Oyj LEI code: 743700YUG3JFXUHHP957
Inderes Oyj share ticker: INDERES
Inderes Oyj share ISIN code: FI4000348651

2. Send a copy of your notification to the Financial Supervisory Authority as an email attachment to Inderes

• Send a copy of the text or a PDF attached to an email to ir@inderes.fi.
• Please also include a phone number where you can be reached if Inderes has any questions about the
notification.
• Do not send the form by mail due to the short time limit!
• If you experience any problems, please contact ir@inderes.fi

Inderes will publish the notification it has received as a company release immediately upon receipt of the notification and no later than three business days after the transaction has taken place.

Click here for more information about the rules governing transaction notifications by managers and persons closely associated with them.