Insider Administration

In its operations, Netum complies with the Market Abuse Regulation (EU No. 596/2014, “MAR”) and the Securities Markets Act, as well as the related regulations and instructions issued by the European Securities and Markets Authority (ESMA), the Financial Supervisory Authority and Nasdaq Helsinki Oy. In addition, the company has its own insider guidelines, approved by its Board of Directors. Netum’s insider guidelines define operating instructions and procedures for the management of insider matters, the disclosure of insider information, the maintenance of insider lists and the transactions of management personnel. The company’s management personnel and all other personnel are personally responsible for ensuring compliance with the company’s insider guidelines.

Netum’s management and persons involved in Netum’s performance reporting are subject to a closed period prior to the publication of financial results, which begins 30 days before the publication of the business reviews, the half-year report and the financial statements bulletin. The company’s managers, in accordance with the Market Abuse Regulation, are the members of Netum Group Plc’s Board of Directors, the CEO and the members of the Management Team. During the closed period, Netum’s management and those involved in Netum’s performance reporting are not permitted to trade or engage in other transactions involving Netum’s financial instruments. Management ownership and transaction

Netum maintains a project-specific insider list of such projects that are insider information. A project-specific insider may not trade Netum shares or other financial instruments during the project’s validity period.

The company has appointed an insider officer responsible for preparing and maintaining insider lists, managing trading restrictions, and the obligation to notify and disclose transactions, internal communications related to insider matters, insider training, and the supervision of insider matters.