Insider issues

Bioretec maintains project-specific insider lists in which all persons who have, de facto, received the inside information and who work for the company under an employment contract or otherwise perform tasks through which they have access to inside information, are recorded. The project-specific insider list is not public.

Person recorded in project-specific insider list and other persons who have inside information pertaining to Bioretec in their possession are prohibited from trading in Bioretec's financial instruments, cancelling or amending an order to acquire or dispose of such financial instruments, recommending another person to trade in such financial instruments or inducing another person to trade in such financial instruments.

Persons discharging managerial responsibilities within Bioretec shall not execute any transactions on their own account or for the account of a third party in Bioretec's financial instruments prior to the announcement of the company's business review report, half-year report or financial statements bulletin during a period commencing 30 days before the announcement of the company's business review report, half-year report or financial statements bulletin and ending at the end of the day subsequent to the publication day of such report (closed window). Should the financial statements contain material information that has not been published previously in the financial statements bulletin, such as future prospects, the closed window applies also to the financial statements.

In addition, Bioretec has decided to apply the closed window also to persons participating in the preparation and drafting of Bioretec's business review reports, half-year reports or financial statements bulletins bulletins and other persons defined by the company (the company’s trading restriction).

Persons discharging managerial responsibilities who are subject to the notification obligation and persons subject to the company's trading restriction shall always prior to executing a transaction in the company's financial instruments confirm with the company's person in charge of insider issues that there is no obstacle for executing the transaction. The transaction in Bioretec's financial instruments shall not be executed until the person in charge of insider issues has granted permission for the transaction and the transaction must be executed within two weeks of the permission.

However, each person is always personally responsible for ensuring that trading in Bioretec's share or other financial instruments, advising on trading in Bioretec's share or other financial instruments or disclosing inside information to another person has been carried out in accordance with Bioretec's insider guidelines as well as existing laws, regulations and guidelines.

Persons discharging managerial responsibilities within Bioretec and persons closely associated with them shall notify their transactions in Bioretec's financial instruments to Bioretec and the Finnish Financial Supervisory Authority promptly and no later than three business days after the transaction. Bioretec discloses such transactions through company releases without delay, but no later than two working days after receipt of the notification.

The Finnish Financial Supervisory Authority shall be notified of transactions exceeding the annual threshold of EUR 20,000. However, the company must be notified of all transactions, and the company notifies the Finnish Financial Supervisory Authority of transactions exceeding the annual threshold.

The notifications shall be made using FIN-FSA's electronic services at web address https://asiointi.finanssivalvonta.fi/en/login

Information requested on the form:
LEI code: 7437008736AG7HY51K13
Trading code of the shares: BRETEC
ISIN code: FI4000480454