Insider Management

Titanium complies with Finnish legislation on insider matters as well as Regulation (EU) No 596/2014 of the European Parliament and Council on market abuse (“MAR”) and its implementing acts and guidelines, along with Nasdaq Helsinki Oy’s insider guidelines. Additionally, the company has its own insider policy approved by the board of directors.

Titanium publishes insider information concerning the company as soon as possible. Under certain conditions, Titanium may delay the publication of insider information, in which case an insider list for that information is prepared. The company does not maintain a permanent insider list for permanent insiders.

Closed Window

Members of Titanium’s board, CEO, or executive management may not conduct transactions in Titanium’s financial instruments on their own behalf or on behalf of a third party during a closed window period. Transactions are prohibited during the 30-day closed window prior to the publication of the company’s financial statements or interim reports, as well as on the publication date. If the financial statements contain previously undisclosed material information, the closed window also applies to the financial statements.

Notification Obligation for Management and Their Close Associates

Members of the board, the CEO, executive management, and their close associates must notify Titanium and the Financial Supervisory Authority of any transactions in Titanium’s financial instruments carried out on their own behalf without delay and no later than three business days after execution. Titanium, in turn, must publish the transaction as a management transaction promptly, and no later than two business days after receiving the notification.