Insiders

The Incap Group’s Guidelines for Insiders comply with the NASDAQ OMX Helsinki’s Guidelines for Insiders, which came into effect on 9 October 2009, and they have been posted on the company’s website. The Guidelines for Insiders have been distributed to all insiders and the compliance with the Guidelines is supervised by, for example, reviewing the information on insiders and their trading once a year.

According to the company’s Guidelines for Insiders, permanent insiders may not trade in the company’s shares or equivalent securities in the 14-day period before the publication of an interim report or the financial statement bulletin. The appropriate time for such trading is within 28 days from the publication of an interim report and financial statement bulletin, nevertheless with the provision that a person who is a permanent insider does not have in his or her possession at that time any other insider information. The members of the Board of Directors and the Management Team as well as the secretary to the Board of Directors must always ascertain the appropriateness of their own trading by checking with the person in charge of insider issues prior to ordering the purchase or sale of shares. Persons who are temporary insiders must not engage in trading in the company’s shares during the time when they are insiders participating in a particular project.

The Group’s permanent insiders are recorded in a register kept by Euroclear Finland Ltd. The register is divided into a public and non-public register. The public register includes the members of the Board of Directors, the Auditor and the deputy Auditor, the President and CEO and the Management Team. The non-public register includes Incap employees who have regular access to insider information in the course of their duties and whom the President and CEO has specified as insiders. A register of project-specific insiders is kept by Corporate Administration.