12. Main procedures relating to insider administration

Fingrid complies with the Market Abuse Regulation (MAR), Nasdaq Helsinki Oy’s insider guidelines as well as the UK’s Financial Conduct Authority’s (FCA) and the Financial Supervisory Authority’s (FIN-FSA) up-to-date guidelines on the governance and management of insider information. Fingrid additionally has insider guidelines approved by the Board of Directors, which describe the key principles for insider issues to be applied within the company. The company’s general counsel, Marina Louhija, is in charge of insider administration.

Fingrid’s permanent insiders consist of the Board of Directors, President & CEO, members of the executive management group as well as any person considered to regularly have access, due to their duties, to insider information concerning Fingrid. Project-specific lists of insiders are drawn up as necessary; such lists include any persons in charge of preparations for the project who have access to insider information related to the project. Fingrid additionally applies a so-called extended closed window to the persons who participate in the preparation of the half-year report, management reviews and/or financial statements, including any external consultants and experts.

The lists related to Fingrid’s insider administration are not public; only the person in charge of insider administration and his/her assistants have access to them.

According to Fingrid’s insider guidelines, permanent or project-specific insiders and the persons under the extended closed window rules may not, on their own account or on the account of a third party, trade in Fingrid’s financial instruments within thirty (30) days prior to the publication of Fingrid’s financial statements release and the regularly published half-year report release and management reviews.