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Insider administration

In insider matters, Titanium complies with Finnish legislation and Regulation No. 596/2014 of the European Parliament and of the Council on market abuse (“MAR”) and supplementary regulations and regulations as well as Nasdaq Helsinki Ltd’s insider guidelines. In addition, the company has its own insider guidelines approved by its Board of Directors.

Titanium discloses inside information directly concerning the company as soon as possible. Under certain conditions, Titanium may postpone the disclosure of inside information, in which case it draws up an insider list for the inside information. The company does not maintain an insider list of permanent insiders.

Closed window

A member of Titanium’s Board of Directors, CEO or member of the Executive Team may not carry out transactions on Titanium’s financial instruments on their own behalf or on behalf of a third party during a closed period. Transactions may not be carried out during a closed period of 30 days prior to the publication of the company’s financial statements bulletin and interim report or on the publication date. If the financial statements contain material information not previously disclosed in a financial statements release, the closed window also applies to the financial statements.

Reporting obligation of managers and their related parties A member of Titanium’s Board of Directors, the CEO, a member of the Executive Team and their related parties must report transactions carried out with Titanium’s financial instruments on their own behalf to both Titanium and the Financial Supervisory Authority without delay and no later than three working days after the transaction has been carried out. Titanium, on the other hand, must publish the transaction in question as a transaction of a manager without delay and no later than two working days after receipt of the notification of the transaction.