Insider information

Ilmarinen maintains public insider register pursuant to the Act on Employment Pension Insurance Companies.

The register contains, as required under said Act, information about holdings in shares admitted to trading on a regulated market or on a multilateral trading facility in Finland, and in such financial instruments the value of which is determined on the basis of said shares.

According to said Act, the insiders of an employment pension company include:

1) a member and alternate member of the Board of Directors, the Managing Director and alternate Managing Director of the employment pension insurance company as well as an auditor, an alternate auditor and an employee of an auditing firm with main responsibility for the audit of the company;

2) other individual in the employ of the employment pension insurance company, who is in a position to influence decision-making concerning the investment of the company’s funds or who otherwise regularly gains access to inside information pertaining to such shares or financial instruments.

In addition to the applicable legislation, Ilmarinen also complies with the Nasdaq OMX Helsinki Ltd (Helsinki Stock Exchange) insider guidelines to the extent possible for an non-listed mutual employment pension insurance company. Ilmarinen also has its own insider guidelines approved by the company’s Board of Directors. Ilmarinen maintains a project-specific insider register in compliance with the instructions. The purpose of the instructions is to make the handling of insider issues more consistent and effective within Ilmarinen.

The data on the holdings of public insiders is available for viewing in the NetSire service maintained by Euroclear Finland.