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Insiders

Sponda complies with the Insider Guidelines issued by NASDAQ OMX Helsinki Ltd. These recommend that insiders wishing to trade in the company’s shares do so at times when the market has the fullest possible information on matters that might materially affect 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 or annual reports.

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 have regular access to insider information by virtue of their role or duties. The project-specific insider register lists the names of individuals to whom the company discloses to insider information regarding a particular project. The holdings of the company’s public insiders are available for inspection in the insider register maintained by Euroclear Finland Ltd. The register of public insiders is also available on the company website at www.sponda.com.