Insider management

In insider matters, Nightingale Health Plc and its group companies comply with the EU Market Abuse Regulation ((EU) 596/2014 as amended, ”MAR”) and with the subordinate provisions issued pursuant thereto as well as with the Finnish Securities Markets Act (746/2012 as amended, ”SMA”), guidelines issued by the competent authorities, and the applicable rules and the Guidelines for Insiders issued by Nasdaq Helsinki Ltd.

Nightingale Health’s Insider Policy applies to all of its employees as well as to the members of the Board of Directors. The Insider Policy is made available to the management and employees of Nightingale Health.

Nightingale Health’s Chief Legal Officer is responsible for the insider matters of the company and is also responsible for maintaining insider lists and managing trading restrictions as well as transaction notifications and publishing duties on behalf of the company.

Management transactions

A manager and persons closely associated with them must notify the Finnish Financial Supervisory Authority and Nightingale Health of any transactions related to the company’s financial instruments they conclude without delay and at the latest within two working days of the said transactions. Nightingale Health has a page on its website containing information to the managers and their closely associated persons on how to make and deliver the transaction notification. Nightingale Health will publish the transaction notifications it receives by publishing a company release without delay and no later than two business days after receipt of notification of the transactions from a manager or a person closely associated with them.

Trading restrictions

Nightingale Health applies the trading restriction applicable to persons discharging managerial responsibilities (i.e. members of the Board of Directors, CEO and members of the Management Team) as set out in MAR (closed window). The closed window period begins 30 calendar days before the publication of the company’s financial statements or half-year report and ends on the day after the publication day of the relevant financial statements or half-year report. Additionally, Nightingale Health has separately identified persons who contribute to the preparation of the company’s financial reports or who have access to information pertaining to this and who are not allowed to directly or indirectly trade in or to conclude any transactions on their own behalf or on the behalf of a third party that relate to Nightingale Health’s shares or to its debt instruments or to related derivatives or other financial instruments.