Oriola-KD complies with the insider holding guidelines of the Helsinki Exchanges of 1 June, 2008, which serve as the basis for the Company’s internal insider guidelines adopted by the Board. The public insiders of Oriola-KD comprise the members of the Company’s Board, its auditors, President and CEO and other members of the management team and the secretary to the Board. Persons in the employ of the Company who have regular access to insider information by virtue of their position or duties make up the Company’s company-specific insiders. In addition, the Company maintains a project-specific register of insiders. Persons privy to insider information concerning a specific project are entered in this register. The public and company-specific registers of insiders are kept in the Euroclear Finland SIRE system.