Insider administration

Terveystalo has its own insider policy (Terveystalo insider policy) which observes the applicable EU legislation, especially the Market Abuse Regulation (EU 596/2014, "MAR"), the regulations given by the Commission under MAR, and regulations and instructions given by the European Securities and Markets Authority (ESMA) or other entities pursuant to MAR, as well as Finnish legislation, especially the Securities Markets Act (746/2012, as amended) and the Finnish Penal Code (39/1889, as amended), Nasdaq Helsinki Ltd’s rules and guidelines for insiders and the guidance of the Finnish Financial Supervisory Authority.

According to Terveystalo insider policy, the Company’s management and their closely associated persons are required to notify the Company and the FIN-FSA of every transaction, defined by MAR, conducted on their own account relating to the Financial Instruments of (or linked to) the Company. The Company discloses this information. The Company has determined that the management, as defined by MAR, include, for the purposes of Terveystalo, members of the Board of Directors and the senior executives in the following positions:
CEO;
CFO;
SVP, Legal; and
SVPs of business lines with P&L responsibility

Based on Terveystalo’s company and governance structure, the above group of persons is deemed to comprise the senior executives who have
regular access to inside information relating to the Company and power to take managerial decisions affecting the future developments and
business prospects of the Company.