Insider management

Alma Media Corporation’s Board of Directors has approved Alma Media Group’s Guidelines for Insiders. The Guidelines for Insiders are based on the Market Abuse Regulation, Level 2 Commission Regulations and the rules and guidelines issued by the European Securities and Markets Authority (ESMA), and they supplement the valid provisions of Nasdaq Helsinki Ltd’s Guidelines for Insiders, Chapter 51 of the Finnish Criminal Code, the Finnish Securities Markets Act and the regulations and guidelines issued by the Finnish Financial Supervisory Authority regarding the management and handling of insider information.

Insiders are divided into two categories at Alma Media Corporation: managers subject to the notification obligation and project insiders.

At Alma Media Corporation, the following shall be considered managers subject to the notification obligation: the Chairman of the Board and the Deputy Chairman, the members of the Board and any deputy members, the CEO and any deputies to the CEO, and the members of the Group Executive Team. Managers subject to the notification obligation shall not trade in the Company’s financial instruments before the publication of the Company’s interim reports and financial statement release within a time frame beginning 30 days before the publication of the interim reports and the financial statement release and ending on the day following the publication date (“closed window”). Project insiders shall not trade in Alma Media Corporation’s financial instruments until the project in question has ended.

Alma Media Corporation has further decided that the persons involved in the preparation and drafting of Alma Media Corporation’s interim reports and financial statement releases Permanent insiders must not trade with financial instruments issued by the Company before the publication of the Company’s interim reports and financial statement releases within a time frame beginning 30 days before the publication of the interim reports and the financial statement release and ending on the day following the publication date (“extended closed window”). The extended closed window also applies to persons who, in the course of performing their duties, obtain information on Alma Media Group’s sales figures or the sales figures of a business unit that has material significance to the result of the Alma Media Group as a whole.

In conjunction with the entry into force of the Market Abuse Regulation on 3 July 2016, the Company introduced a whistleblowing channel “Almawhistleblow”, which is an independent channel for the Company’s employees to report suspected non-compliance with regulations such as the Market Abuse Regulation and other regulations governing the financial markets.

Alma Media Corporation shall disclose transactions by managers and their closely associated persons involving the Company’s financial instruments by issuing a stock exchange release in accordance with the Market Abuse Regulation.

The public insider register was discontinued on 3 July 2016 and Euroclear Finland Oy’s NetSire register has not been updated since 2 July 2016.

The Company’s General Counsel is responsible for the insider management of the Alma Media Group.