Corporate Governance

Insider management

The company’s insider administration complies with the EU Market Abuse Regulation (MAR) and Nasdaq Helsinki’s rules, which are supplemented by the company’s own insider guidelines. The Company’s insider guidelines apply to the company, Persons Discharging Managerial Responsibilities (PDMRs) within the company, and those employees of the Company who have access to inside information or who have otherwise become aware of inside information. In addition, these insider guidelines apply on a contractual basis to other persons acting for or on behalf of Auroora when they perform tasks through which they have access to inside information.

Persons Discharging Managerial Responsibilities (PDMRs) within the company and any permanent insiders defined by the company may not carry out transactions involving Auroora’s financial instruments, either directly or indirectly, for their own account or for the account of a third party during a closed period (closed window)., which always begins 30 days prior to the publication date of the company’s financial statements release, half-year financial report and the company’s regularly published three- and nine-month interim reports, and ends at the time of publication of the group’s interim report, half-year financial report or financial statements release (closed period).

In accordance with the insider guidelines of Nasdaq Helsinki, Auroora determines that persons who have participated in the preparation, drafting, review or disclosure of the company’s financial reports may not carry out transactions involving Auroora’s financial instruments for their own account or for the account of a third party during the closed period referred to in the preceding paragraph.

The company’s Chief Financial Officer acts as the insider officer and is responsible for insider administration duties. He or she is also responsible for maintaining insider lists. Practical tasks relating to insider lists and the management of inside information are carried out by a person designated by the insider officer.

The Chief Financial Officer or a deputy designated by him or her is responsible for managing the trading restriction applicable to management and closely associated persons, as well as the notification and disclosure obligations relating to transactions.

Instructions for reporting transactions

In accordance with MAR, Persons Discharging Managerial Responsibilities at Auroora and their close associated persons must notify the company and the Finnish Financial Supervisory Authority of any transactions they have made with Auroora’s financial instruments.

The notifications shall be made to Auroora Group Plc and the FIN-FSA promptly and no later than three business days after the date of the transaction (T+3).

Notification process:

1. Transactions will be notified via electronic services at https://asiointi.finanssivalvonta.fi/en/login.

Service-specific instructions for using electronic services can be found here.

Information needed on the form:

• LEI code: 743700SNJLIHHMNMRM35
• Trading code of the shares: AUROORA
• ISIN code: FI4000586409

2. The person subject to notice obligation must copy the information in the notification and send it without delay by email to the company at ville.peltonen@auroora.com after the notification has been sent to the Financial Supervisory Authority via electronic means.