Insider governance

Note: this translation is unofficial.

Purpose and scope of the insider policy

The Board of Directors of Springvest Corporation has confirmed an insider policy, which serves as a practical tool for managing insider matters.

The policy is based on the following insider regulations:

Market Abuse Regulation (596/2014/EU, as amended)
Market Abuse Directive (2014/57/EU, as amended)
Commission Delegated Regulation (2016/522/EU, as amended)
Commission Implementing Regulation (2016/347/EU and 2016/523/EU, as amended)
National legislation, in particular Chapter 51 of the Criminal Code (39/1889, as amended) and the Securities Markets Act (746/2012, as amended)
Nasdaq Helsinki Oy’s insider guidelines and exchange rules
Guidelines issued by the Financial Supervisory Authority.

Prohibitions on the use of inside information

The Company, its personnel, and any parties involved in the Company’s insider projects at any given time are subject to rules on the use of inside information and, in particular, the prohibition on its use.

During the closed period, the person concerned may not carry out transactions in Springvest’s financial instruments – for example, trading in Springvest shares is prohibited.

Quiet period

In accordance with its disclosure policy, Springvest also observes a quiet period. The quiet period before the publication of interim reports and the annual financial statements is thirty (30) days.

During the quiet period, Springvest does not comment on its financial data subject to reporting. During the quiet period, Springvest’s management also does not give interviews concerning information to be published for the first time in financial reports, nor does it meet with investors or appear at capital market events.

Publication and delay of inside information

When inside information arises, it must either A) be published as soon as possible, or B) a decision must be made to delay its publication and an insider list must be established.

Conditions for delaying publication

Delaying inside information is only possible when the following conditions for making the delay decision are met:

the immediate publication of inside information would likely jeopardise Springvest’s legitimate interests;
the delay in publication would not likely mislead the public; and
the confidentiality of the information can be guaranteed.

If the grounds for delay are met, Springvest may, at its own responsibility, make the decision to delay. It should be noted, however, that the publication of a profit warning cannot be delayed.

Insider projects and insider lists

Inside information ceases to be inside information when it has been published or when the insider project has lapsed.

If Springvest has made a decision to delay the publication of inside information and has established an insider list, those persons entered on the insider list are prohibited from carrying out transactions in Springvest’s financial instruments. This means, for example, that trading in Springvest shares is prohibited.

End of the trading prohibition

The trading prohibition related to insider projects ends when the insider project concludes, either through publication or the lapsing of the project.

The person entered on the insider list will be notified by email of the conclusion of the project and the end of the trading prohibition.

Handling of inside information and leak situations

The decision-making and publication process regarding the disclosure of inside information is carried out in accordance with the procedures set out in Springvest’s current disclosure policy.

Springvest’s disclosure policy also defines procedures for situations where inside information is leaked.

Whistleblowing procedure

Springvest has in place a procedure through which those employed by the Company can report suspected violations of rules and regulations through an independent channel (“whistleblowing”).

This procedure also covers suspected violations of rules and regulations relating to financial markets. The whistleblowing reporting procedure is described in a separate policy.

Responsibilities for insider governance

Insider governance at Springvest is centralised with the person responsible for insider matters, i.e. the General Counsel. The person responsible for insider matters at Springvest also provides guidance on confidentiality procedures for each insider project.

When Springvest’s General Counsel is unable to act, the CEO of Springvest is responsible for insider matters.

Last updated 11 March 2026.