Insider Administration

United Bankers Plc (”United Bankers”) complies with the EU Market Abuse Regulation that entered into force on 3 July 2016 (”MAR”), as well as with Nasdaq Helsinki Ltd’s Guidelines for Insiders of Listed Companies. The Board of Directors of United Bankers has approved the internal policy regarding inside information and trading permit procedure, which defines the procedures for the management of inside information and trading to be abided by within the United Bankers Group.

United Bankers’ Insider Administration is responsible for monitoring compliance with the internal policy regarding inside information and trading permit procedure, MAR, Nasdaq Helsinki Ltd’s Guidelines for Insiders of Listed Companies, and any other issued insider regulations, as well as for training and advising in insider matters. Furthermore, Insider Administration is responsible for the maintaining of insider registers, granting trading permissions as well as for notifications to the management and the Finnish Financial Supervisory Authority.

The personnel of the United Bankers group companies (employees, officers and tied agents) undergo regular training in insider matters. The person responsible for insider matters reviews the information entered in the insider register with the insiders on a quarterly basis, in addition to which the person responsible for insider matters reviews the compliance with trading restrictions within the United Bankers Group on a quarterly basis.

At United Bankers, the person responsible for organising the Insider Administration is the Group’s Head of Compliance. In addition to the Head of Compliance, also the Compliance Officer and the person responsible for insider matters are a part of the Insider Administration at United Bankers Group.

Insider registers

United Bankers maintains an insider register, containing a listing of the persons in possession of inside information regarding any given project. A project-specific insider register is employed in matters or arrangements being prepared on a confidential basis that owing to their nature or magnitude deviate from United Bankers’ customary business operations or the strategy published by the company, and when the company at the time of the assessment has objectively evaluated that the measures or arrangements under preparation may be reasonably presumed to actualise. United Bankers evaluates on a case-by-case basis, whether the matter or arrangement under preparation is to be considered a project. In conjunction with the establishment of an insider project, also the fulfilment of the prerequisites for delaying the disclosure of inside information is assessed, and a decision is made regarding the delaying of the disclosure of inside information pertaining to the project.

Persons entered in a project-specific insider register are notified in writing of their entry into the register as well as of the obligations and consequences pertaining to same, and at the end of the project of the cessation of the project and of the obligations. A person entered in a project-specific insider register is not allowed to trade with financial instruments issued by United Bankers.

In addition to the project-specific insider registers, United Bankers maintains a supplementary section of the insider register comprising the permanent insiders, containing information of the persons with constant access to all inside information within a company. Such persons include members of the group’s Executive Management and the Executive Management’s assistant, the Chief Financial Officer, Finance Manager, persons working in the Legal & Compliance functions, Risk Manager, Investor Relations Manager and the Human Resources Director.

The insider register and its supplementary section do not constitute public documents.

Transactions of the Management and the persons closely associated with them

The MAR regulation obligates United Bankers to maintain a register of persons acting in managerial positions and of the persons closely associated with them. Persons holding managerial positions in United Bankers and the persons closely associated with them are obligated to notify United Bankers and the Finnish Financial Supervisory Authority of any transactions carried out in their name with United Bankers’ shares or debt instruments, or any related derivatives or other financial instruments. United Bankers publishes the above-mentioned transactions by means of a stock exchange release within three (3) working days of the actualisation of the transaction. The stock exchange releases are available in the company’s archive of stock exchange releases.

Members of the management subject to the disclosure of information include members of United Bankers’ Board of Directors, the Chief Executive Officer, members of the Executive Management, as well as the company’s Chief Financial Officer and finance manager. The register of the persons under the disclosure obligation and of the persons closely associated with them is not public.

Subsidiaries’ insider registers

The United Bankers Group operates within the field of investment services, and the insider regulation pertaining to investment service companies and fund management companies obligates certain of the United Bankers Group subsidiaries to maintain their own insider registers. The investment service companies UB Securities Ltd and UB Asset Management Ltd belonging to the United Bankers Group must pursuant to the Finnish Act on Investment Services, and the fund management company UB Fund Management Company Ltd pursuant to the Finnish Act on Common Funds, maintain a public insider register of the persons belonging to the circle of insiders and of their holdings.

In the United Bankers Group, the following persons are deemed to constitute insiders of investment service companies and of the fund management company:

1) a member and the deputy member of the Board of Directors of the investment service company and of the fund management company, Chief Executive Officer and the Chief Executive Officer’s deputy, other persons belonging to the top management along with their deputies (persons factually managing the business), as well as the auditor, deputy auditor and officer of an auditing entity with principal responsibility for the company’s audit;

2) a person employed by an investment service company, whose task is to conduct investment research concerning shares or financial instruments, whose principal task is to participate in the provision of investment services or who otherwise regularly obtains inside information concerning such shares of financial instruments; and

3) a person employed by a fund management company or acting on behalf or in the name of same, who is able to impact in the decision-making concerning the assets of the mutual fund.

Trading restrictions and closed period

Pursuant to the United Bankers Group’s internal trading permit procedure, members of the Board of Directors of the United Bankers group companies, as well as persons employed by the United Bankers Group and the tied agents must always request a prior written permission from the person responsible for insider matters for trading with financial instruments issued by United Bankers prior to the execution of the transaction.

United Bankers Plc follows a closed period, starting 30 days before the publication of a half-year financial report or a financial statements bulletin and lasting until the end of the publication date. During the closed period, members of the Boards of Directors of the United Bankers group companies, persons employed by the United Bankers Group, as well as tied agents and the persons closely associated with them (an incompetent person, whose guardian the aforementioned person is and the aforementioned person’s or the incompetent person’s controlled communities) must not trade with financial instruments issued by United Bankers.

Members of the Board of Directors of the United Bankers group companies, persons employed by the United Bankers Group, as well as tied agents and the persons closely associated with them (an incompetent person, whose guardian the aforementioned person is and the aforementioned person’s or the incompetent person’s controlled communities) must not engage in so-called short selling with financial instruments issued by United Bankers. Short selling refers to trading in which the time period between the buying and selling, or, similarly, between selling and buying, of a financial instrument is under one (1) month.