Disclosure policy

Note: this is unofficial translation.

General

In all its communications, Springvest complies with the EU Market Abuse Regulation (“MAR”), other regulations and applicable legislation, Finnish law, the Nasdaq Helsinki Ltd Nasdaq First North Growth Market Rulebook rules and insider guidelines, and the rules, guidelines and regulations of ESMA (European Securities and Markets Authority) and the Financial Supervisory Authority.

The purpose of the disclosure policy is to define the principles that Springvest follows in its external communications and investor relations. The key objective of the disclosure policy is to ensure that all market participants have equal and simultaneous access, as quickly as possible, to sufficient and material information about the company and its business operations as a basis for the correct pricing of the company’s securities.

The key principles of the company’s communications are timeliness and equality, consistency and continuity, and honesty and transparency.

The company’s Board of Directors approved the disclosure policy on 9 November 2021, and it will be updated as necessary. The Chief Executive Officer of the company is responsible for maintaining the disclosure policy and overseeing its implementation.

Responsibilities for communications and investor relations

The Chief Executive Officer is responsible for the company’s investor communications.

Ernst & Young Oy acts as the company’s Nominated Adviser in accordance with the Nasdaq First North Growth Market Rulebook rules.

Communication channels

The company’s primary channel for up-to-date information is its website at www.springvest.fi. All material information relating to the company is published in Finnish through STT Finland Oy, to the key media, and on the company’s website at www.springvest.fi.

Reporting and publication languages

The company’s official reporting and publication language is Finnish.

Company announcements

Springvest discloses insider information and other matters required to be published under the Nasdaq First North Growth Market Rulebook by means of a company announcement, such as financial statements information, notices of general meetings and decisions of general meetings, significant changes in company management, and proposals and decisions on share issue authorisations.

Company announcements are available on the company’s website for at least five (5) years from the date of their publication.

Management transactions

Springvest discloses transactions in Springvest financial instruments by persons discharging managerial responsibilities under MAR and their closely associated persons within two (2) business days of receiving notification of the transaction. The aforementioned obligation is based on Article 19 of MAR. The notification obligation begins when the value of the transactions of those subject to the obligation exceeds the threshold of EUR 20,000 during a calendar year.

Springvest is not responsible for the accuracy of information reported by management persons or their closely associated persons.

Quiet period and closed period

The company observes a thirty (30)-day quiet period prior to the publication of results. During that period, the company’s representatives do not meet or communicate with capital market representatives or financial media.

Springvest observes a thirty (30)-day closed period in accordance with MAR, during which persons discharging managerial responsibilities at Springvest may not trade on their own account or on behalf of a third party in the company’s shares, debt instruments, related derivatives or other financial instruments, or carry out other transactions. Springvest also applies the closed period to persons who are involved in or who have access, by virtue of their duties, to results information during its preparation phase.