In its insider administration, the Company follows the Market Abuse Regulation (EU No 596/2014) and the rules of Nasdaq Helsinki complemented by the Company’s own Insider Policy. The Company maintains its own insider registers. The Company does not have permanent insiders.

Persons in managerial positions are prohibited to carry out transactions (on their own account or for the account of a third party), directly or indirectly, in the financial instruments of the Company during a closed period of 30 calendar days before the announcement of each of the interim reports or the year-end report (financial statement release). The Company applies the closed period of 30 calendar days immediately preceding the announcement of the interim report or financial statement release, as the case may be, including the date of publication of such report (the “Closed Window”). The prohibition is in force during the Closed Window regardless of whether or not such a person holds any inside information at that time. A project-specific insider list is maintained when required by law or regulations. Project-specific insiders are prohibited from trading in the Company’s financial instruments until the termination of the project.

Persons in managerial positions (and their closely associated persons) are obligated to report transactions in the Company’s financial instruments in line with applicable EU and domestic laws and regulations. The members of the Board and the Management team are the managers of the Company with an obligation to disclose their transactions.

Managers’ Transactions

Persons in managerial positions (and their closely associated persons) are obligated to notify the Company and the FIN-FSA of transactions in the company’s financial instruments in line with applicable EU and domestic laws and regulations. The members of the Board, the CEO, the CFO, the Senior Vice President Radiators and the Senior Vice President ICS are designated as persons with an obligation to disclose their transactions.

Instructions regarding notifications of Management Transactions

The Company’s managers and their closely associated persons referred to in the Market Abuse Regulation ((EU) No 596/2014, “MAR”) are requested to follow the instructions below  for notifying transactions. Such notifications shall be made to the Company and FIN-FSA promptly and no later than three (3) business days after the date of the transaction.

The Company discloses via stock exchange releases information on transactions by managers and their closely associated persons, to the extent notified in writing to the Company. A stock exchange release is submitted by the Company promptly upon its own receipt of each notification from a manager (or closely associated persons) no later than two (2) business days after the receipt of the notification.

Instructions for filling in and sending of transaction notification:

• In accordance with MAR, each Manager must notify to the Company and the FIN-FSA of every transaction in the Financial Instruments of the Company conducted on his/her own account.
• The notifications shall be made no later than three (3) business days after the date of the transaction (T+3). The Company recommends that an informal notice is given (investors@purmogroup.com) already on the date of the transaction and before the notification is submitted through the FIN-FSA’s electronic services portal.
• The notification shall be sent to the Company (IR) and to the FIN-FSA.
• The notification shall be sent to the FIN-FSA via the FIN-FSA’s electronic services portal available at https://asiointi.finanssivalvonta.fi/en/login (click FIN-FSA identification service or go to https://asiointi.finanssivalvonta.fi/kirjaudu to create the login details for the first time you submit the notification to FSA and the Company) and include the information specified therein. When reaching the third page (Summary) of the electronic notification web page, you can see the notification you have completed in both XML format and as a summary in stock exchange release format. Copy this information from the page and email it to the Company (investors@purmogroup.com) who is required to disclose the notification information.
• When reaching the fourth page (Submission) of the electronic notification web page, you can download the notification you have made as an attachment in pdf format. Click the ‘Send’ button to send the notification to the FIN-FSA.

Information needed for the notification:

• Purmo Group Plc’s LEI code: 743700JHE9365SIHRE72
• Purmo Group Plc’s share ticker: PURMO
• ISIN codes of Purmo Group’s share: Class C Share: FI4000507488, Class F Share: FI4000507470
• Notification reference: Generated automatically (no need to fill in)

Additional detailed instructions on using the FIN-FSA’s electronic services portal available can be found at https://www.finanssivalvonta.fi/en/about-the-fin-fsa/financial-supervisory-authority-e-services/managers-transactions/.

If a Manager authorises another person (e.g. insider officer of the Company or an asset manager) to make the notifications on its behalf, information thereof (and the contact details of the relevant authorised persons, when necessary) shall be submitted to the Company in writing. Such authorisation does not relieve the Manager from his/her liability.

For further information, please contact investors@purmogroup.com.