For Investors

Fodelia Oyj’s Disclosure Policy

In all its communications, Fodelia complies with the EU Market Abuse Regulation (“MAR”), other regulations and applicable legislation, Finnish law, the rules of Nasdaq Helsinki Oy’s Nasdaq First North Growth Market Rulebook and its insider guidelines, as well as the rules, guidelines and regulations of the European Securities and Markets Authority (ESMA) and the Financial Supervisory Authority.

The purpose of the disclosure policy is to set out the operating principles that Fodelia adheres to in its external communications and investor relations. The key objective of the disclosure policy is to ensure that all market participants have equal access, at the same time and as soon as possible, sufficient and relevant information about the company and its business operations to serve as a basis for the correct pricing of the company’s securities.

The key principles of the company’s communications are timeliness and impartiality, consistency and continuity, as well as honesty and transparency.

The Company’s Board of Directors approved the disclosure policy on 4 November 2019, and it is updated as necessary. The Company’s Chief Executive Officer is responsible for maintaining Fodelia’s disclosure policy and for overseeing its implementation.

Areas of responsibility for communications and investor relations

The Chief Executive Officer is responsible for the company’s investor communications.

Ernst & Young Oy acts as the company’s approved adviser in accordance with the Nasdaq First North Growth Market Rulebook.

Communication channels

Fodelia’s main channel for up-to-date information is the company’s website at www.fodelia.fi. All material information concerning the Company is published in Finnish via Cision Finland Oy, to key media outlets and on the Company’s website at www.fodelia.fi.

Languages of reporting and publication

The company’s official reporting language is Finnish.

Company Announcements

Fodelia discloses, via company announcements, inside information and other matters required to be disclosed under the Nasdaq First North Growth Market Rulebook, such as financial statement information, notices of general meetings and resolutions passed at such meetings, significant changes to the Company’s management, and proposals and resolutions concerning share issue authorisations.

Company announcements are available on the company’s website for five years following their publication.

Transactions by management

Fodelia announces, in accordance with the MAR:transactions relating to Fodelia’s financial instruments carried out by its persons discharging managerial responsibilities and their related parties, in accordance with the notifications received, without delay and no later than three working days after the transaction. The aforementioned obligation is based on Article 19 of MAR. The notification obligation arises when the value of the transactions carried out by the person subject to the notification obligation exceeds the threshold of 5,000 euros during a calendar year.

Fodelia accepts no responsibility for the accuracy of the information provided by senior executives or their related parties.

Quiet period and closed period

The company observes a 30-day quiet period prior to the publication of its results. During this period, company representatives do not meet with or communicate with representatives of the capital markets or the financial press.

Fodelia adheres to the 30-day closed window in accordance with the MAR, during which Fodelia’s senior managers are prohibited from trading or carrying out other transactions in Fodelia’s financial instruments. At Fodelia, members of the Board of Directors and the Executive Management Team are defined as senior managers for the purposes of the Market Abuse Regulation. Fodelia also applies the closed window to persons who are involved in, or who, by virtue of their duties, have access to, financial results information whilst it is being prepared.