INSIDER ADMINISTRATION

Incap Group’s Guidelines for Insiders comply with Nasdaq Helsinki Ltd’s Guidelines for Insiders, which came into effect on 1 July 2023. Incap’s Guidelines for Insiders include a summary on principles and company-specific instructions as well as the Nasdaq instructions, and these documents shall be considered together as Incap Corporation’s Guidelines for Insiders. The Guidelines for Insiders of Incap Corporation have entered into force on 12 February 2018 by the decision of the Board of Directors of Incap.

Incap maintains an insider register of persons subject to disclosure obligation (members of the Board of Directors and the Management Team) as well as of persons who regularly have access to inside information due to their positions or tasks (secretary to the Board, finance team managers) as well as of other persons who work with the company on the basis of some other agreement and have regular access to the inside information.

Trading by Incap’s insiders is forbidden 30 days before the release of an interim report, a half-year report, a financial statements bulletin or any other financial report. An appropriate time for trading is within 28 days of the publication of an interim report, a half-year report, a financial statements bulletin or any other financial report, provided that the insider does not at that time possess any other inside information, such as on a project that is under preparation.

Persons who become insiders due to their involvement in a project are not permitted to trade in Incap shares or warrants while they are project-specific insiders.

Changes in the holdings of insiders are disclosed in stock exchange releases, which the company publishes in accordance with the MAR regulation.

Incap Corporation’s Insider instructions valid as from 12 February 2018

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