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Insider Management

Olvi plc complies with the insider guidelines of Nasdaq Helsinki Ltd valid at each time. Furthermore, the Board of Directors of Olvi plc has confirmed the company’s own insider guidelines that supplement those issued by Nasdaq Helsinki Ltd ( Guidelines for Insiders). The guidelines clarify and supplement the practices of the company and the insiders and serve as a practical tool for handling insider issues. Each insider is always personally responsible for ensuring that his or her actions comply with the regulations given in law, the Financial Supervision Authority’s standard and the insider guidelines.

The Market Abuse Regulation ((EU) No 596/2014, “MAR”) entered into force on 3 July 2016. As a consequence of the MAR, the company no longer has public insiders. The company maintains a permanent company-specific insider register of persons who receive inside information due to their tasks or position, as well as insider lists specific to projects and events, but these are not public.

Managers’ holdings ((EU) No 596/2014, “MAR”)

Olvi plc’s managerial employees subject to a notification obligation* have provided their written consent for public presentation of their shareholdings on the company’s Web site > Managers’ holdings*.

Silent period

Olvi plc observes a closed window of 30 days. Trading in the company’s financial instruments is not allowed in the period preceding the publication of the company’s interim reports and financial statement bulletin. The period begins 30 days before publication and ends on the day following the publication. Should an event occur during the silent period that requires the disclosure of information, Olvi plc shall make a disclosure without undue delay in accordance with the applicable regulations, and may comment the event in question.

Project-specific insiders are not allowed to trade in the company’s shares or comparable securities during the period in which they belong to project-specific insiders.

Whistle Blowing

Olvi plc has a feedback channel through which Olvi Group employees may anonymously report any suspected violations of financial market legislation and regulations within the listed company (whistle blowing). The feedback is collected by corporate administration.

Supervision

Compliance with the guidelines is regularly supervised in accordance with instructions issued by the Board of Directors of Olvi plc.

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