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INSIDERS

Insider Administration

Afarak complies with the Guidelines for Insiders issued by the NASDAQ OMX Helsinki Stock Exchange.

Public Insider Register

The Company’s permanent public insiders comprise the Board members, the CEO, the Executive Management Team and the auditors. All permanent public insiders and the statutory information about them, their related parties and the entities controlled by them or in which they exercise influence, have been entered into the Company’s public insider register which is published on the Group’s website and is published in the 2012 Corporate Governance Statement.

Afarak imposes a restriction on trading for insiders which forbids trading in the Company’s shares for 30 days before the publication of financial reports. Prior to the preliminary announcement of the Company’s annual results and the publication of its annual financial report the closed period is 60 days or, if shorter, the period from the end of the relevant financial year up to and including the time of the announcement.

Compliance with the insider regulations is monitored by taking samples at certain intervals of trading by insiders in the Company’s shares.

Company-specific Insider Register

In addition to the public insider register, the Company holds a company-specific insider register of persons who regularly receive information that can have material impact on the value of its securities. These persons include all Afarak employees and third-party service providers who regularly obtain insider information.

Project-specific Insider Register

When necessary, the Company sets up a separate project-specific insider register. Project-specific insiders are those who, in connection with the insider project, obtain information about the Group that might have material impact on the value of the Company’s shares if it were published. The establishment of a project is decided by the Board or the CEO.

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